Background
Randy and Evgenia Quaid appealed the district court’s dismissal with prejudice of their claims against various defendants arising from a land dispute in California. The district court also declared the Quaids to be vexatious litigants and ordered them to pay attorneys’ fees to defendant-appellee Berman.
The court’s reasoning
The Ninth Circuit reviewed the dismissal de novo and the vexatious litigant declaration for abuse of discretion. The court held that the litigation privilege barred the Quaids’ claims for invasion of privacy and conspiracy against the Turicchi Defendants, Fidelity Defendants, and Williams because the claims stemmed from communications made in judicial proceedings. The court further found that the Quaids failed to comply with the claim presentation requirement of California’s Government Claims Act when suing the County Defendants. The court also affirmed the dismissal of the slander of title claim against Berman as functionally adjudicated and the declaration of the Quaids as vexatious litigants.
What it means going forward
The decision reinforces the absolute nature of the litigation privilege in California for communications made in judicial proceedings and confirms strict adherence to the Government Claims Act is required before suing public entities.