Lots of non-association is … not association

Allegations about a great deal of activity that does not implicate the TCPA,’s protection of the right of association, do not implicate the TCPA’s protection of the right of association: “Tiffany first contends that Rupert’s allegations of conspiracy and joint enterprise meet this standard because they involve the disposition of Marie’s estate (including certain community property) and ‘two decades of publicly filed lawsuits.’ She cites no authority for the proposition that the estate proceedings of a private individual involve public or citizen’s participation, and we have found no such authority. Likewise, we find no authority supporting the notion that extended litigation between and among these parties becomes a matter of public or citizen’s participation merely because of its volume or allegedly repetitive nature. On the contrary, the allegations made by Rupert are of an intensely personal nature, and they address actions involving the personal relationships within the Pollard family.”  Pollard v. Pollard, No. 05-19-00240-CV (Feb. 8, 2021) (mem. op.).