United Locating Services, LLC v. Damon Fobbs, Rodney Johnson, & Carlos Harrell
United Locating Services, LLC appealed the denial of its motion to dismiss under the Texas Citizens Participation Act (TCPA) in a lawsuit brought by former employees Damon Fobbs, Rodney Johnson, and Carlos Harrell. The former employees sued United for defamation and invasion of privacy, alleging that United continued to use their names on work orders and damage tickets after their employment. The appellate court determined that the former employees' claims fell within the TCPA's scope. However, the court found that the former employees failed to establish by clear and specific evidence a prima facie case for each essential element of their claims, specifically regarding the 'value associated with their names' for the appropriation claims and 'publication' and 'actual malice or negligence' for the defamation claims. The trial court's order denying the motion to dismiss was reversed, and the case was remanded for a determination of attorney's fees, court costs, and sanctions to be awarded to United.