Camper v. Paramount Global, 2026 WL 836249, No. B339150
(Cal. Ct. App. Mar. 26, 2026)
Camper “viewed a trailer for the reality television show
College Hill: Celebrity Edition, which referenced, but did not show, a physical
altercation between two cast members.” Camper alleged that he was misled by the
trailer and other promotional materials to believe the show would include the
full altercation and therefore paid for a subscription to the online streaming
service BET Plus. When the show did not include any additional footage of the
altercation, he sued for false advertising and related claims.
The trial court granted Paramount’s anti-SLAPP motion to strike.
Camper alleged that the trailer showed an argument between
two of the show’s stars about racial identity, then showed one getting up to
confront the other, then cut to other cast members yelling. Based on the
trailer, “media interviews regarding the season, and a circulated screenshot of
a physical fight released by” respondents, Camper allegedly bought a
subscription to BET Plus so he could watch College Hill. At the moment of the
fight, the show displayed the following message, “Out of respect for all
parties involved, we have chosen not to show this fight.”
Paramount denied releasing the screenshot presented by
Camper, or “any other screenshot depicting a physical altercation” between the
cast members, “as part of an official marketing campaign or for any other
purpose.” It also argued that it did not exercise any control over the
interview given by a cast during which she discussed the fight, since by the
time the interview was recorded, she had been expelled from college and had
left the cast of College Hill.
The trial court concluded that the television program and
associated promotional activities constituted protected speech in connection
with an issue of public interest, as the episode involved “discussions of
issues regarding race and racial identity, and the physical fight that is at
the center of [Camper’s] claim arose out of a dispute on that topic.” Camper’s
claims under the UCL, FAL, and CLRA failed because he could not establish that
“it is probable that a significant portion of the general consuming public or
targeted consumers could be misled by the trailer.” The court found that the
physical altercation “was depicted in the episode, with a level of graphic
detail that was greater than that in the trailer,” including that it showed an
“opening swing” by one cast member, followed by “an extended segment of violent
and disturbing audio that leaves no doubt that a physical fight is occurring,”
as well as “audio of other classmates’ reactions during and after the event.”
The trial court found that the scene “is much more dramatic than what is shown
in the trailer, and nothing that is in the trailer is left out of the scene.”
The court further noted that “there is nothing in the trailer that indicates
how the fight would actually be depicted in the episode.”
The court of appeals agreed. Camper argued that the trial
court should have applied an exception for commercial speech, but the
anti-SLAPP law carves out an exception from the commercial speech exception when
an action is “based upon the creation, dissemination, exhibition,
advertisement, or other similar promotion of any dramatic, literary, musical,
political, or artistic work, including, but not limited to, a motion picture or
television program.”
Camper had no evidence that a significant portion of
reasonable consumers viewing the College Hill trailer could be misled to
believe that the show would include additional footage of the physical fight. Declarations
from Camper and one other viewer regarding their expectations were insufficient,
especially since all of the footage in the trailer related to the fight was
shown during the episode, as well as audio recordings capturing the fight and
onlookers’ reactions to it. (Nor did he show causation given that he subscribed
before the cast member interview.)
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