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Marc Randazza


Alex Shepard


Case Overview

Daphne Williams purchased a condo from a friend of hers, using real estate agent Charles “Randy” Lazer. Williams filed a complaint against Lazer with the Nevada Real Estate Division, alleging that he acted unprofessionally, unethically, and with discriminatory behavior. After the NRED initially found that Lazer had violated ethics standards, it later rescinded this decision.

Lazer sued Williams for defamation based on the NRED complaint, but Williams filed an Anti-SLAPP motion, seeking to dismiss the claim. The district court denied the motion, ruling that Williams had not made her statements in the complaint in “good faith.” Williams then filed another Anti-SLAPP motion, but the district court denied it again, and also found that complaints to NRED were not privileged.

Williams appealed to the Nevada Supreme Court, which reversed the lower courts’ decisions, finding that Williams’s opinions were not the same as knowledge of falsity for purposes of the “good faith” requirement. The Supreme Court also created new law in Nevada by ruling that NRED complaints are entitled to an absolute privilege because they are statements made in a “quasi-judicial proceeding.”

After the Supreme Court’s decision, Williams was awarded almost $170,000 in costs and fees due to the lower courts’ errors that caused the case to go on longer than necessary.

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