Amitay v. Jews for Jesus CA1/2

── Amitay v. Jews for Jesus CA1/2 ── Court: California Court of Appeal Date: May 28, 2026 Category: General Filed 5/28/26 Amitay v. Jews for Jesus CA1/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION TWO ARIEL ZVOLON AMITAY, Plaintiff and Respondent, A174056 v. (San Francisco County Super. Ct. JEWS FOR JESUS, No. CGC-24-620902) Defendant and Appellant. Ariel Amitay, an Orthodox Jewish rabbi, sued defendant Jews for Jesus (or JFJ), an evangelistic Christian ministry, for defamation and related claims based on social media postings by defendant that featured his photograph. JFJ filed a special motion to strike the complaint under the anti-SLAPP statute (Code Civ. Proc., § 425.16).1 The trial court denied the motion, finding that Amitay showed his claims had at least “minimal merit” to survive an anti-SLAPP motion. JFJ appeals. We find no error and affirm. BACKGROUND Jews for Jesus describes itself as an “evangelistic” ministry that “shares the Gospel of Christ to [its] Jewish brothers and sisters, both here in 1 “ ‘SLAPP’ is an acronym for ‘strategic lawsuit against public participation.’ ” (Baral v. Schnitt (2016) 1 Cal.5th 376, 381, fn. 1 (Baral).) 1 the United States and around the world.” According to JFJ’s executive director, JFJ has expanded its “evangelistic” “outreach” to social media over the years. In December 2023, JFJ posted on its social media pages, including on Facebook and Instagram, a blurred photograph of an Israeli soldier wearing a yarmulke. Above the photograph was the following text attributed to “Nachman”: “ ‘Thank you for leaving at my home a copy of the New Testament. I look forward to reading it when I return home from the war’ – Nachman, a young Haredi soldier.”2 3 Amitay filed a complaint against JFJ, attaching screenshots of JFJ’s posts. He alleged that the photographs posted by JFJ were photographs of him, that they had been posted without his consent, and that defendant had defamed him, put him in a false light, and inflicted emotional distress. Amitay alleged that he was a Jewish Orthodox rabbi who had “dedicated his life to the study of the Jewish Orthodox faith and committed many years studying to become a rabbi,” recounting about a dozen years of study. He had finally gotten a job teaching at an institution in Israel where he had worked for two years, a position he described as his “dream job.” His job “suddenly came to an end as he was terminated . . . due to an egregious act by JFJ,” 2 “Hasid is the Hebrew word for ‘pious.’Hasidic Jews, or Hasidim, are the largest sub-group of Haredi Jews. Haredim are sometimes referred to as ‘ultra-Orthodox,’ although this term may be considered objectionable.” (Young Advocates for Fair Education v. Cuomo (E.D.N.Y. 2019) 359 F.Supp.3d 215, 221, fn. 4.) 3 Some of the posts went on to state: “One of the ways that God provides for His people is through the generosity of other people around the World, like you. Because of your support, we were able to give a copy of the New Testament to Nachman and more than 1,000 Israelis in 2023!” 2 namely, “upload[ing] photos of Amitay on [its] social media pages.” He alleged: “JFJ posted a picture of [him] on their website giving the appearance that he