A Strategic Lawsuit against Public Participation, (SLAPP) is a suit in which the plaintiff sues an organization or person in an attempt to silence, intimidate, or punish s into dropping protests against the plaintiff. SLAPPs have been directed against individuals and groups that have spoken in public forums on a wide variety of issues, particularly against real estate development, the actions of public officials, environmental damage or pollution, and unwanted land use. They have also been used against those who have worked publicly for the rights of consumers, workers, women, minorities, and others. A number of states have passed laws intended to prevent SLAPPs and protect the right to participate in public activism. Washington is the first state to pass an anti-SLAPP law in 1989. By 1996 eight other states — California, Delaware, Massachusetts, Minnesota, Nebraska, Nevada, New York, and Rhode Island — had passed such laws.