New Jersey Appellate Court Upholds Anti-SLAPP Protections in Case Involving a Dispute Over Man's Refusal to Give a Get (Jewish Divorce)

NJ Court Sends Message to a Man Who Refused to Give His Wife a Religious Divorce a Message: You Can't Silence Your Critics with a SLAPP (Strategic Lawsuits Against Public Participation)

On May 29, 2025, the New Jersey Appellate Division issued an important decision in in Satz v. Starr, reversing a lower court ruling and reinforcing the state’s commitment to protecting free speech under its newly enacted Anti-SLAPP law—the Uniform Public Expression Protection Act (UPEPA).

What Happened in Satz v. Starr?

The case began when Allen J. Satz filed a $30 million lawsuit against the Organization for the Resolution of Agunot (ORA), The Jewish Link, Bies Medrash of Bergenfield, Keshet Starr, and Rabbi Neal Turk—after they circulated a flyer urging him to grant his wife a "get" or Jewish religious divorce. The flyer included Satz’s photo and called for a protest outside his parents’ home.

Satz later voluntarily dismissed the lawsuit, but the defendants sought to recover legal fees under the UPEPA. The trial court denied their motion, but the Appellate Division reversed that decision, holding that the defendants were entitled to pursue their claim for attorney’s fees and costs under the Anti-SLAPP statute—even after the case was dismissed.

This ruling is a significant affirmation of the UPEPA’s purpose: to deter Strategic Lawsuits Against Public Participation (SLAPP) and protect individuals and organizations from being silenced through costly litigation.

Why This Decision Matters

The Satz decision is the first published appellate opinion interpreting New Jersey’s Anti-SLAPP law. It sends a clear message: New Jersey courts will not tolerate attempts to chill free expression through litigation. For individuals, media outlets, and advocacy organizations, this ruling offers reassurance that speaking out on matters of public concern is not only a right—but one that is now firmly protected by law.

The decision helps provide:

• Stronger shield for speakers.  Anyone sued for speech in New Jersey now has real assurance that SLAPP plaintiffs cannot sidestep the fee-shifting hammer by pulling the plug at the last minute.

  
  

• Clear roadmap for trial judges.  Going forward, courts must assess (1) whether the challenged lawsuit targets protected expression on a matter of public concern and, if so, (2) whether the plaintiff can establish a prima facie case. If the plaintiff fails, dismissal with prejudice and an award of costs follow.

  
  

• Bigger risk for would-be SLAPP filers.  Plaintiffs must now reckon with the near-certainty of paying the other side’s legal bills if their claims encroach on First-Amendment-protected activity.

Practical Take-Aways for Businesses, Journalists, Non-Profits, Journalists, and Other Individuals Facing a SLAPP

1. Act quickly.  A UPEPA motion must be filed within 60 days after service of the complaint.

   
   

2. Preserve the record.  Keep screenshots, correspondence, and publication dates that show your speech addressed a public matter.

   
   

3. Leverage the automatic stay.  Once a UPEPA motion is filed, discovery and other costly procedures are paused until the court rules.

What Should You Do If You’re Targeted by a SLAPP?

If you believe you’re facing a Strategic Lawsuit Against Public Participation, it’s critical to act quickly. The UPEPA provides a narrow window to file a motion to dismiss the case under the Uniform Public Expression Protection Act (UPEPA). At Kemeny, Ramp & Renaud, LLC, we help clients navigate these complex cases and can assist with asserting your rights under New Jersey’s Anti-SLAPP law.