Background
Randy and Evgenia Quaid appealed a district court dismissal with prejudice of their claims against various defendants arising from a land dispute in California. The district court also declared the Quaids vexatious litigants and ordered them to pay attorneys’ fees to defendant Berman. The claims included invasion of privacy, public disclosure of private facts, conspiracy, and slander of title.
The court’s reasoning
The court affirmed the dismissal of claims against the Turicchi Defendants, Fidelity Defendants, and Williams because they were barred by the absolute litigation privilege under California law. The court found that the claims stemmed from communications made in judicial proceedings to achieve the objects of litigation. Regarding the County Defendants, the court held that the Quaids failed to comply with the Government Claims Act requirement to present claims before filing suit, rejecting arguments of substantial compliance or futility. The slander of title claim against Berman was affirmed as functionally adjudicated on the merits, and the vexatious litigant declaration was affirmed as the plaintiffs waived any challenge to it.
What it means going forward
The ruling reinforces the broad scope of California’s litigation privilege in shielding participants from tort liability for communications in court proceedings and confirms strict adherence to claim presentation statutes for suits against public entities.
Podcast (federal-narrative-summaries): Play in new window | Download