The Second Appellate District affirmed in part and reversed in part trial court orders and remanded. The court held that an attorney’s protected petitioning activities under the anti-SLAPP statute does not include either criminal activity or activity which adversely impacts a person with no connection to the underlying litigation.

A romantic relationship between Robert Pfeifer and Erin Finn ended. Feifer filed several civil complaints against Finn. Pfeifer was represented by law firm Gaims, Weil, West & Epstein, LLP (Gaims). Gaims retained a private investigator who, in turn, conducted illegal wiretaps of Finn’s telephone conversations.