A California judge has seriously hobbled a lawsuit by the shock-rocker known as Marilyn Manson against one-time girlfriend Evan Rachel Wood, who has accused him of sexual abuse.
Manson — whose real name is Brian Warner — had sued Wood, an actress, and her girlfriend Ashley Gore in March 2022, alleging defamation and intentional infliction of emotional distress. He says the couple plotted to fabricate sexual abuse allegations against him and pressured other women to do the same. Manson, who has admitted to threatening at least one woman with rape and violence, alleged that Wood and Gore spent years secretly enlisting women to accuse him and even coordinated a falsified letter to the FBI on the topic, all to strengthen their film project.
In Feb. 2021 Wood publicly accused Manson, her former fiance, of being the rapist whose brutal crimes Wood had detailed to a congressional subcommittee three years prior. Wood graphically described severe sexual abuse at Manson’s hands, and after she named him as her accused abuser, multiple women spoke out and said they had been similarly victimized by the performer.
In court documents, Manson called Wood’s allegation that he is a rapist “a malicious falsehood that has derailed Warner’s successful music, TV, and film career.”
Wood and Gore filed a motion to dismiss under California’s anti-SLAPP statute, which seeks to limit “strategic lawsuits against public participation” aimed at chilling free speech. Although the case was not entirely thrown out, Judge Teresa Beaudet, in a 37-page ruling, essentially gutted Manson’s case. It was the only the latest volley in the legal ping-pong between the rocker and the couple, who have denounced him as a violent predator.
Beaudet struck Manson’s emotional distress claim, which had been based on the allegedly falsified FBI letter and the “checklist” Manson said Wood and Gore provided to women in an effort to fabricate abuse allegations. Manson said that the letter, which had been submitted by Wood as part of a California custody proceeding, was forged “to create the false appearance that Warner’s alleged ‘victims’ and their families were in danger, and that there was a federal criminal investigation of Warner ongoing.” Wood denied fabricating the letter.
The judge did not rule on whether the FBI letter was authentic, but found that even if it was forged, it was used in litigation and therefore “protected activity” for purposes of the anti-SLAPP statute.
Beaudet also ruled that whatever use Wood and Gore may have made of a checklist regarding women who would potentially go public with claims against Manson was not enough to rise to the level of “extreme and outrageous conduct” required to support an emotional distress claim.
Beaudet struck a blow directly to the heart of Manson’s defamation case when she ruled that many of Wood and Gore’s activities fell into a “protected” category under California’s anti-SLAPP statute, because advocating against sexual violence is a matter of public interest. Beaudet’s finding on protected speech shifts the burden to Manson to prove that his lawsuit did not violate the statute.
Although some claims still remain against wood and Gore, Beaudet’s ruling seriously weakens Manson’s legal position.
Manson and Wood, an actress and star of HBO’s “Westworld,” were in a romantic relationship from 2006 to 2010. Wood and Gore, an artist who also goes by the name Illma Gore, have been together since 2019, according to Manson’s complaint
Wood is now the CEO, CFO, and corporate secretary of Phoenix Act, a nonprofit organization that advocates for victims of domestic violence. Gore, a non-binary Australian artist, made headlines in 2016 when she was punched in the face by a Donald Trump supporter for having painted an unflattering picture of a naked Trump.
In 2019, Wood and Gore began working on an HBO documentary series called “Phoenix Rising,” which chronicled Wood’s work with the namesake organization.
“We are very pleased with the Court’s ruling, which affirms and protects Evan’s exercise of her fundamental First Amendment rights,” said Michael Kump, attorney for Evan Rachel Wood in an email. “As the Court correctly found, Plaintiff failed to show that his claims against her have even minimal merit.”
Manson’s attorney Howard King said in a statement to Law&Crime that the ruling is “disappointing but not unexpected,” and indicated that Manson intends to appeal. He criticized the judge for excluding what he described as “critical evidence” in his client’s favor.
The trial on Manson’s remaining claims has been set for May 1, 2024.
Have a tip we should know? [email protected]