California attorney · CA Bar #279869

California defamation attorney

I'm Sergei Tokmakov, a California attorney. Defamation cases in California are time-sensitive (one-year SOL under CCP § 340(c)) and risky to file because CCP § 425.16 anti-SLAPP can shift fees to the plaintiff if the case is weak. I run the attorney letter, the anti-SLAPP risk analysis, and the strategic call before anything gets filed.

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Cal. Civ. Code §§ 44
Quick answer

California defamation has three controlling pieces. Civ. Code §§ 44 (defamation defined), 45 (libel), and 46 (slander, including slander per se for criminal conduct, professional incompetence, loathsome disease, and unchastity) set the substantive elements. CCP § 340(c) gives one year from publication to sue, with limited discovery extension. CCP § 425.16 anti-SLAPP allows defendants in cases arising from protected speech to file a special motion to strike at the start of the case, with mandatory attorney-fee shifting to the prevailing defendant. AB 933 (Civ. Code § 47.1, effective 2024) creates a privilege for survivors who publicly disclose sexual assault, harassment, or domestic violence. The anti-SLAPP exposure is why filing a weak defamation case in California is a financial mistake; the attorney letter often resolves the matter without ever needing to file.

1-year SOL
Per CCP § 340(c)
Anti-SLAPP
CCP § 425.16 risk
Per se
Categories per Civ. § 45a
Retraction
Civ. § 48a demand rule
Fact vs opinion (lite)
Quick 60-second triage on a statement

Was the statement provable fact, mixed, or pure opinion?

Verdict
Pick one to see the lane
Tap Fact / Mixed / Opinion above.
Run the full 5-question Statement Risk Classifier below →I am not your attorney; this is illustrative only.

What I do for California defamation matters

1

Screen anti-SLAPP exposure first.

Anti-SLAPP under CCP § 425.16 kills defamation cases at the pleading stage. I screen the case for protected-speech and public-issue exposure before any complaint moves toward filing.

CCP § 425.16
2

Send the § 48a retraction demand on time.

Civ. § 48a requires a retraction demand within 20 days for newspaper/broadcast cases. I send the demand on time so the special damages remain available.

Civ. § 48a
3

Plead defamation per se where it fits.

Civ. § 45a categories of defamation per se (criminal imputation, professional misconduct, loathsome disease, unchastity) shift damages to presumed-damages framework. I plead per se when the facts support it.

Civ. § 45a
4

Calendar the 1-year SOL under § 340(c).

Defamation has a 1-year SOL. I calendar the SOL from publication or republication so the case is filable on time. On the $1,200 tier I add the draft complaint.

CCP § 340(c)
Anti-SLAPP warning. California defamation is the one practice area where filing a complaint without careful pre-filing analysis is a financial mistake. CCP § 425.16(c) requires the court to award the prevailing defendant attorney fees on a granted anti-SLAPP motion. Fee awards in the $50,000-$200,000 range are common. The $575 package focuses on the letter plus the risk analysis precisely because the filing decision needs separate evaluation after the letter phase. If filing is right after the letter phase, that scope is quoted separately based on specific facts.

Why this calls for an attorney, not a takedown notice

DIY / template

What a self-written letter misses

  • Walks into an anti-SLAPP buzzsaw
  • Misses the retraction demand under Civ. § 48a
  • Cannot plead defamation per se under § 45a
  • Lets the 1-year SOL run
Attorney letter

What the attorney letter does

  • Screens anti-SLAPP exposure before filing
  • Sends the § 48a retraction demand on time
  • Pleads defamation per se when categories apply
  • Calendars the CCP § 340(c) one-year SOL

Anti-SLAPP exposure is what kills defamation cases, the memo screens the case before the complaint ever gets filed.

The controlling law

Cal. Civ. Code §§ 44, 45, 46.

§ 44 defines defamation as either libel or slander

§ 44 defines defamation as either libel or slander. § 45 defines libel as "a false and unprivileged publication by writing, printing, picture, effigy, or other fixed representation to the eye, which exposes any person to hatred, contempt, ridicule, or obloquy, or which causes him to be shunned or avoided, or which has a tendency to injure him in his occupation." § 46 defines slander and lists four categories of slander per se: criminal conduct, infectious or loathsome disease, professional incompetence, and unchastity (now read more narrowly post-Eisenberg v. Insurance Co. of North America, 815 F.2d 1285 (9th Cir. 1987)). Per se defamation presumes damages without specific proof.

Cal. Civ. Proc. Code § 340(c).

One year from publication for defamation actions

One year from publication for defamation actions. The single-publication rule applies in California: each separate publication starts its own clock. Online content is treated as a single publication for the original post, with edits or re-posts potentially constituting new publications under fact-specific analysis.

Cal. Civ. Proc. Code § 425.16 (anti-SLAPP).

Defendants in cases arising from protected speech may file

Defendants in cases arising from protected speech may file a special motion to strike at the start of the case. Step one of the analysis asks whether the conduct sued upon arose from protected speech (statements made in legislative, executive, or judicial proceedings; statements in places open to the public on issues of public interest; petitioning activity). Step two asks whether the plaintiff has shown minimum merit on the claim. If step one is met and step two fails, the motion is granted and the defendant recovers attorney fees under § 425.16(c). The fee shift is mandatory.

Cal. Civ. Code § 47.1 (AB 933).

Signed in 2023 and codified at § 47.1, this

Signed in 2023 and codified at § 47.1, this provision creates a privilege for individuals who publicly disclose having been a victim of sexual assault, harassment, or domestic violence. The privilege limits defamation liability for survivors who speak publicly. A defamation case against a survivor about their disclosure faces this privilege as a defense plus anti-SLAPP exposure.

Constitutional framework.

New york times co

New York Times Co. v. Sullivan, 376 U.S. 254 (1964), requires actual malice for public-figure defamation cases. Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974), distinguished public and private figures and established negligence as the floor for private-figure cases. Section 230 of the Communications Decency Act (47 U.S.C. § 230) immunizes online platforms from liability for user-generated content, which means the user (not the platform) is the right defendant.

The settlement math. Defamation cases in California typically settle around three elements: takedown of the offending content (often the most valuable to the client), retraction or apology (sometimes more valuable than money), and a smaller dollar payment for damages and lost business. Cases that go to verdict can produce six-figure damages for serious harm to reputation and economic loss, but the cost of the case (and the anti-SLAPP exposure on a weak filing) makes settlement the right strategy for most matters. The attorney letter is the optimal vehicle for getting to the right settlement quickly without triggering anti-SLAPP risk.
5-question risk classifier

Statement Risk Classifier

Five quick questions, then a strength score. The classifier weighs the same factors I use when deciding whether to send a $575 letter, write a $349 evaluation memo, or tell a client to walk away.

Question 1 of 5
Was the statement made as fact, or as opinion?
Question 2 of 5
Was the statement published to a third party?
Question 3 of 5
Can you prove the statement is false?
Question 4 of 5
Did you suffer specific damages?
Question 5 of 5
Are you a public figure or private figure?
Your case
Strength score
0
Step 1 / 5
Risk scoring is illustrative and based on the five factors I weigh most heavily. Actual case strength depends on the exact statement, publication context, witness availability, and anti-SLAPP exposure under CCP § 425.16. Email me at owner@terms.law for case-specific analysis.

What clients send me

The strongest defamation letter is built from the exact statement and the evidence of falsity. Before drafting, I ask for:

  • The exact statement at issue, with publication date and venue (website URL, social-media platform, newspaper, broadcast)
  • Screenshots or archived copies of the publication, with timestamps and any version history
  • The speaker's identity (real name, online handle, any known contact information)
  • Documentary evidence of falsity: records, contracts, communications, or other proof that the statement is not true
  • Your status: are you a public figure (politician, celebrity, executive of a public company), a limited-purpose public figure (involved in a specific public controversy), or a private figure
  • The audience: how widely the statement has been disseminated, how many views or shares, any business or personal consequences
  • Economic damages: lost contracts, lost employment, declined business, with documentation
  • Any communications you've had with the speaker about the statement (request for retraction, response from speaker)
  • The speaker's relationship to you: former employee, ex-partner, business rival, anonymous online actor
  • Whether you've spoken publicly about the underlying events at issue (relevant for § 47.1 analysis)

If documentation is incomplete, send what exists. I tell you what's missing and how that affects the analysis before quoting.

What I send back

Note: Filing a complaint after the letter phase is scoped separately based on the anti-SLAPP analysis and the negotiation outcome. The $575 package does not include a draft complaint because defamation filings need to clear minimum-merit review before they're worth the fee-shift risk.

How the engagement runs

1
Send facts

Email a paragraph + key documents.

2
Identify theory

I map the facts to the CA statute.

3
Draft letter

Attorney letter on letterhead.

4
You approve

Two revision rounds included.

5
Send certified

USPS certified + email delivery.

6
Negotiate

Three negotiation responses included.

Choose your path

Start here if

Case memo

$349
  • You want a written legal evaluation first
  • You may refer to a contingency firm later
  • Statute or evidence questions are unsettled
Accept memo - $349
Start here if

Demand + draft lawsuit

$1,200
  • Counterparty needs to see the lawsuit is real
  • Multiple claims or institutional defendant
  • You may file pro se after the demand
Accept package - $1,200

Pricing

Frequently asked questions

You
What counts as defamation in California?
S
Civil Code § 44 defines defamation as either libel (written, § 45) or slander (oral, § 46). The elements are: (1) a publication of a false statement of fact (not opinion), (2) about the plaintiff, (3) to a third party, (4) with the required fault (negligence for private figures, actual malice for public figures), and (5) causing damages. Certain categories (criminal conduct, professional incompetence, loathsome disease, unchastity) are defamation per se under § 46, which means damages are presumed. The statement must be a verifiable fact, not opinion or hyperbole.
You
What is the statute of limitations on California defamation?
S
One year from publication under CCP § 340(c). The single-publication rule means each separate publication starts its own clock (a magazine article that runs once starts one clock; an online post can be complicated by edits or republication). Discovery rules apply narrowly. The short limitations period is one of the reasons defamation cases need to move quickly: a six-month-old defamatory post gives six months to send the letter, evaluate the anti-SLAPP risk, and decide whether to file.
You
What is anti-SLAPP and why does it matter?
S
California's anti-SLAPP statute (CCP § 425.16) allows defendants in cases arising from protected speech (any statement on a matter of public interest, made in a public forum, in connection with an issue under consideration by official bodies, etc.) to file a special motion to strike at the start of the case. If the motion is granted, the case is dismissed and the defendant recovers mandatory attorney fees from the plaintiff under § 425.16(c). Anti-SLAPP is broad in California and applies to many types of speech (online reviews, social-media posts about public figures, statements to police or regulators, news reporting). The plaintiff in a defamation case has to win the anti-SLAPP motion to proceed, which means the case has to survive minimum-merit review or the plaintiff pays the defendant's lawyer.
You
Why does anti-SLAPP change the strategy?
S
Filing a weak defamation case in California is risky because of the fee shift. A plaintiff who files, loses an anti-SLAPP motion, and faces a $50,000-$200,000 fee award is in a worse position than before filing. The strategy in California defamation work is to assess anti-SLAPP exposure before filing, not after. The attorney letter often does the work without ever needing to file: many defendants take down the defamatory statement, issue a retraction, or settle once they see a credible letter. The cases that proceed to court are the cases that have already passed the anti-SLAPP minimum-merit test in the lawyer's pre-filing analysis.
You
What damages are recoverable in defamation cases?
S
Defamation per se cases (criminal conduct, professional incompetence, loathsome disease, unchastity) presume damages, which means plaintiffs do not need to prove specific harm. Defamation per quod requires proof of special damages. Compensatory damages cover reputation harm, emotional distress, and economic loss (lost business, lost job). Punitive damages are available where actual malice is proven, with the constitutional limits set by State Farm v. Campbell and BMW v. Gore. The damages package in a defamation case is reputational repair plus the dollar number; many cases settle with takedown, retraction, and a smaller dollar payment because the takedown is the primary value.
You
What is AB 933 / Civ. Code § 47.1?
S
AB 933, signed in 2023 and codified at Civ. Code § 47.1, creates a privilege for individuals who publicly disclose having been a victim of sexual assault, harassment, or domestic violence. The privilege limits defamation liability for survivors who speak publicly about their experiences. A defendant who threatens a survivor with a defamation case after the survivor's public disclosure faces the § 47.1 privilege as a defense plus anti-SLAPP fee exposure. The statute changes the landscape for both sides; survivors have stronger protections, and plaintiffs threatening defamation against survivors face heightened risk. I assess § 47.1 in the pre-letter analysis.
You
What about online review platforms and Section 230?
S
Section 230 of the Communications Decency Act (47 U.S.C. § 230) generally immunizes online platforms (Yelp, Google, Glassdoor, Reddit) from liability for content posted by users. The platform itself is not the right defendant; the user who posted the content is. The platform may remove content in response to a court order or its own policies, but it cannot be sued for the third-party post. The demand letter usually goes to the user (when identifiable) or the platform's legal notice department for content removal where the platform's policies allow.
You
Can I get a defamatory post taken down?
S
Sometimes, depending on the platform's policies and the strength of the defamation claim. Google, Yelp, Glassdoor, and other major platforms have content-removal procedures for court-ordered defamation findings; some accept verified defamation determinations and remove the content. A demand letter to the user combined with a separate letter to the platform's legal department often produces takedown without court involvement. The takedown is often the primary remedy the client wants; the dollar damages are secondary.
You
What does the $575 package include?
S
A written anti-SLAPP risk analysis (whether the statement at issue is likely protected speech under CCP § 425.16, the strength of the merit case, and the fee-shift exposure if a motion to strike is granted), plus an attorney demand letter on letterhead citing Civ. Code §§ 44-46 and the one-year statute of limitations. The letter demands retraction, takedown, and damages where appropriate. The letter is sent USPS certified mail with signature requested plus email. Three negotiation responses are included. The package does NOT include filing a complaint; that decision is made after the letter phase based on whether the anti-SLAPP risk has been managed.
You
Why doesn't the package include a draft complaint?
S
Defamation is the one practice area where filing without a careful anti-SLAPP analysis is a financial mistake. The fee-shift exposure on a granted anti-SLAPP motion under § 425.16(c) regularly exceeds $50,000 in defamation cases (the defendant's lawyer's fees through the motion). For that reason, the $575 package focuses on the letter plus the analysis; if filing is the right move after the letter phase, that scope is quoted separately based on the specific facts and the strength of the anti-SLAPP analysis. This is different from other practice areas where the $1,200 letter-plus-draft-lawsuit package makes sense.

Defamed? The clock is one year. Let me run the analysis.

Email me a short paragraph about the statement, the speaker, and when it was published. I'll respond same day with a scoped flat-fee quote.

Email owner@terms.law