A Los Angeles judge on Tuesday (May 9) dismissed much of Marilyn Manson’s defamation lawsuit against his ex-fiance, Evan Rachel Wood, ruling that many of his claims were barred under a California law aimed at protecting free speech.
Manson (real name Brian Warner) sued Wood last year, claiming her 2021 accusations of sexual abuse against him had been false and that she had “secretly recruited, coordinated, and pressured” other women to make similar allegations against him to destroy his career.
But Judge Teresa A. Beaudet ruled Tuesday that Manson had not sufficiently shown that he would ultimately be able to prove many of those accusations against Wood, including that she had been “pressuring multiple women to make false accusations,” as well as the allegation that she had forged a letter from the FBI.
The ruling came under California’s so-called anti-SLAPP statute — a law that aims to make it easier for judges to quickly dismiss cases that threaten free speech. Wood’s lawyers claimed Manson’s case was exactly that: a prominent musician using a lawsuit to try to silence someone who was speaking out publicly about years of alleged abuse.
Anti-SLAPP laws work by putting more burden than usual on defamation plaintiffs like Manson, forcing them to clearly show at the outset that their case is legitimate. In Tuesday’s decision, Judge Beaudet said Manson had failed to do so.
“The court does not find that plaintiff has demonstrated a probability of prevailing on his [intentional infliction of emotional distress] claim based on the FBI Letter,” the judge wrote, referring to one of Manson’s specific legal claims.
Importantly, the decision did not dismiss Manson’s case entirely, and several claims remain pending against Wood. Those claims will continue into discovery and toward an eventual trial. But the ruling was still a major victory for Wood.
In a statement to Billboard following the decision, Wood’s attorney, Michael Kump, said: “We are very pleased with the court’s ruling, which affirms and protects Evan’s exercise of her fundamental First Amendment rights. As the court correctly found, plaintiff failed to show that his claims against her have even minimal merit.”
Wood is one of several women to accuse Manson of serious sexual wrongdoing over the past two years. Manson has denied all of the allegations, and many of the lawsuits filed against him have since been dropped, dismissed or settled.
Manson filed the current lawsuit against Wood in March 2022, accusing her and a woman named Illma Gore of launching an “organized attack” that had derailed his career. His lawyer said the women had carried out “a campaign of malicious and unjustified attacks.”
But Wood quickly fought back, moving to strike Manson’s case under the anti-SLAPP law: “For years, plaintiff Brian Warner raped and tortured defendant Evan Rachel Wood and threatened retaliation if she told anyone about it,” her attorneys wrote. “Warner has now made good on those threats by filing the present lawsuit.”
Tuesday’s ruling came despite a bombshell recantation by Ashley Morgan Smithline, another woman who has accused Manson of wrongdoing. In a February filing submitted by Manson’s lawyers, Smithline said she had “succumbed to pressure” from Wood to make “untrue” accusations against Manson.
But Wood strongly denied those allegations, and Judge Beaudet ultimately refused to consider Smithline’s statements entirely, saying they had been filed far past a key deadline for submitting evidence. That means the statements about Wood’s “pressure” played no role in Tuesday’s decision.
In a statement to Billboard, Manson’s lawyer, Howard King, said the ruling was “disappointing but not unexpected.”
“The court telegraphed this outcome when it refused to consider the bombshell sworn declaration of former plaintiff Ashley Smithline, which detailed how women were systematically pressured by Evan Rachel Wood and Illma Gore to make false claims about Brian Warner,” King said.
“The failure to admit this critical evidence, along with the court’s decision to not consider Ms. Gore’s iPad, the contents of which demonstrated how she and Ms. Wood crafted a forged FBI letter, will be the subject of an immediate appeal to the California Court of Appeal,” King added.
