The Rule of Benjamin Woodhouse v. The State Bar of California et al. is that trial courts have inherent authority to dismiss complaints that assert fantastic, delusional, or fanciful scenarios that have no arguable basis in law or fact, and may declare such plaintiffs vexatious litigants, under circumstances where the complaint presents allegations that no reasonable person would classify as within the realm of possibility.
Appeal from order declaring plaintiff a vexatious litigant in Superior Court, Los Angeles County.
Plaintiff Appellant was Benjamin Woodhouse — an attorney on involuntary inactive status who filed a 53-page complaint containing allegations of decapitations, genocide hotels, assassination attempts, and the incineration of federal judges.
Defendants Respondents were The State Bar of California, Meta Platforms Inc., Nike Inc., Alphabet Inc., and Warner Bros. Discovery Inc. — entities that Woodhouse claimed operated a conspiracy involving mass killings and terrorist activities.
The suit sounded in defamation, fraud, civil RICO, and economic espionage claims. No cross-claims were asserted.
The key substantive facts leading to the suit were Woodhouse's allegations that defendants operated a "genocide hotel" across from his Pismo Beach residence where they decapitated female attorneys, actress Kate Bosworth, court clerks, and minors; hired foreign military forces including Russian and Moldovan troops to conduct over 2,000 assassination attempts against him; incinerated Ninth Circuit Judge Carlos Bea; and executed over 15,000 victims.
The procedural result leading to the Appeal: The trial court granted defendants' motions declaring Woodhouse a vexatious litigant under Code of Civil Procedure sections 391(b)(1) and 391(b)(4), ruling that Woodhouse had filed at least five unsuccessful lawsuits in the preceding seven years, had been previously declared a vexatious litigant by federal courts on similar facts, and that there was no reasonable probability he would prevail on his claims.
The key questions on Appeal: 1. Whether substantial evidence supported the trial court's vexatious litigant finding; 2. Whether the trial court properly determined there was no reasonable probability of success on Woodhouse's claims.
The Appellate Court held that trial courts possess inherent authority to dismiss complaints presenting fantastic, delusional, or fanciful scenarios that lack any arguable basis in law or fact, and that substantial evidence supported both the vexatious litigant designation and the finding of no reasonable probability of success where the plaintiff's allegations described a world no reasonable person would classify as within the realm of possibility.
The case is inapplicable when complaints present seemingly startling claims that could potentially be proven true through evidence, or where allegations, while unusual, do not rise to the level of describing fantastic, delusional, or fanciful scenarios that are completely divorced from reality.
The case leaves open the precise boundaries of what constitutes "fantastic and delusional" allegations warranting summary dismissal, and how courts should distinguish between improbable but potentially provable claims versus those that are entirely divorced from reality.
Counsel
For Appellant: Benjamin Woodhouse in pro. per.
For Respondent State Bar: Office of General Counsel of the State Bar of California, Ellin Davtyan, Kirsten Galler and Raymond R. Rollan
For Respondents Meta and Nike: Gibson Dunn & Crutcher, Kristin A. Linsley and Austin Schwing
For Respondent Warner Bros.: Davis Wright Tremaine and Dan Laidman
For Respondent Alphabet: Wilson Sonsini Goodrich & Rosati, Matthew R. Reed and John B. Kenney