Judge: Ashfaq G. Chowdhury, Case: 24NNCV01328, Date: 2024-10-25 Tentative Ruling

Case Number: ¿24NNCV01328    Hearing Date: October 25, 2024    Dept: E

Hearing Date:  10/25/2024 – 8:30am
Case No.¿24NNCV01328
Trial Date: UNSET
Case Name: DAN SCHNEIDER, an individual, v. WARNER BROTHERS DISCOVERY, INC., a Delaware corporation; MAXINE PRODUCTIONS, a California corporation; SONY PICTURES TELEVISION INC., a Delaware corporation; MARY ROBERTSON, an individual; EMMA SCHWARTZ, an individual; and Does 1-50 inclusive

 

[TENTATIVE RULING ON¿DEFENDANTS’ SPECIAL MOTION TO STRIKE]¿ 

 

PROCEDURAL

Moving Party: Defendants – Warner Bros. Discovery, Inc.; Maxine Productions; Sony Pictures Television Inc.; Mary Robertson; and Emma Schwartz

Responding Party: Plaintiff, Dan Schneider

Moving Papers: Notice/Motion; Pamela Deutsch Declaration; Emma Schwartz Declaration; Michael J. Grygiel Declaration; Notice of Lodging (filed 7/3/2024); Request for Judicial Notice; Proposed Order; Proof of Service; Notice of Lodging (filed 9/20/2024)

Opposing Papers: Opposition; Doug Bania Declaration; Request for Judicial Notice; John Vaccaro Declaration

Reply Papers: Reply; Proposed Order; Defendants’ Evidentiary Objections to John Vaccaro Declaration; Proposed Order Granting Defendants’ Evidentiary Objections to John Vacarro Declaration; Defendants’ Opposition to Plaintiff’s Request for Judicial Notice; Emma Schwartz Reply Declaration; Pamela Deutsch Reply Declaration; Defendants’ Evidentiary Objections to Doug Bania Declaration

Proof of Service Timely Filed (CRC Rule 3.1300(c)): Ok
16/21 Court Days Lapsed (CCP § 1005(b), CRC 3.1300(a)): Ok
Correct Address: (CCP § 1013, § 1013a, § 1013b): Ok

RELIEF REQUESTED¿ 
Defendants Warner Bros. Discovery, Inc., Maxine Productions, Sony Pictures Television Inc., Mary Robertson, and Emma Schwartz, will and hereby do move pursuant to Cal. Civ. Proc. Code § 425.16(b) to strike in its entirety the Complaint filed by Plaintiff, Dan Schneider, and to dismiss the Complaint with prejudice. Defendants’ Motion is made pursuant to California’s anti-SLAPP statute, Cal. Civ. Proc. Code § 425.16, on the grounds that the Complaint’s single cause of action for defamation is based solely upon Defendants’ acts in furtherance of their rights of free speech in connection with a public issue and Plaintiff cannot demonstrate a probability that he will prevail on the merits of his claim.

 

This motion is made following a conference among counsel which took place on June 17, 2024, pursuant to the Court’s directive entered on June 10, 2024.

 

The Complaint is based solely upon Defendants’ acts in furtherance of their First Amendment rights because its defamation claim challenges Defendants’ publication of a five-part documentary, preceded by a Trailer (collectively, the “Documentary”), that investigated the extent to which various inappropriate and abusive conduct took place on the sets of children’s television shows created and produced by Plaintiff for Nickelodeon.

 

Plaintiff will not be able to show a probability of prevailing on his defamation claim for the following reasons:

 

·         The Complaint fails to identify any statement about Plaintiff that is defamatory on its face, and its cause of action sounding in defamation per se is therefore defective as a matter of law;

 

·         The Documentary, which is the basis for the Complaint and is judicially noticeable, does not state, either expressly or by reasonable or clear implication, anything actionable in defamation about Plaintiff, and does not support that Defendants intended any defamatory implication about Plaintiff;

 

·         The Complaint fails to sufficiently plead any facts that would support the allegation that the Documentary was published with actual malice — i.e., with knowledge that the disputed statements and implications were false or with reckless disregard as to whether they were true, and that Defendants intended to communicate the purported implications — much less facts that could satisfy the “clear and convincing” standard applicable, as a matter of law, to defamation actions brought by public figures; and

 

·         Plaintiff has insufficiently pled that he suffered any special damages, and the Complaint does not adequately allege entitlement to other damages because Plaintiff failed to demand a correction as required by California Civil Code § 48a.

 

Accordingly, the Complaint should be dismissed with prejudice.

 

Defendants also seek an award of attorneys’ fees against Plaintiff pursuant to Cal. Civ. Proc. Code §425.16(c). Defendants will submit a supporting declaration and motion for attorneys’ fees should the instant Motion be granted.

 

This Motion is based on this Notice, the attached Memorandum of Points and Authorities, and the concurrently filed Declarations of Emma Schwartz, Pamela Deutsch, and Michael J. Grygiel, the documents attached thereto, Request for Judicial Notice, and such further judicially noticeable evidence or argument as may be presented at the hearing on this motion.”

 

(Def. Mot. p. 2-3.)

 

 

BACKGROUND
Plaintiff, Dan Schneider, filed the instant action on 5/1/2024 against Defendants - Warner Bros. Discovery, Inc.; Maxine Productions; Sony Pictures Television Inc.; Mary Robertson; and Emma Schwartz.

The caption of the Complaint lists a single cause of action titled, “Defamation Per Se Under Civ. Code §§ 44-46 and California Common Law.”

“This action arises out of the recent television docuseries Quiet on Set: The Dark Side of Kids TV (“Quiet on Set”) in which Defendants falsely state or imply that Schneider—a well-known television producer, creator and/or writer responsible for some of history’s most beloved children’s television shows—sexually abused the children who worked on his television shows. These statements are fabrications.” (Compl. ¶ 1.)

Plaintiff alleges that “the voiceovers and graphics in Quiet on Set and its trailer, juxtaposed or edited with the visual depictions, are purposefully and intentionally defamatory in that they falsely and repeatedly state or imply that Schneider is a child sexual abuser and committed crimes in this regard—and have been interpreted as such by countless average, ordinary or reasonable viewers.” (Compl. ¶ 18.)

Plaintiff alleges that Episode 1 falsely and intentionally states and/or implies that Schneider sexually abused children who worked on his shows. (See Compl. p. 9.)

Plaintiff alleges that Episode 2 states and/or implies that, like Convicted Felons Jason Handy and Brian Peck, Schneider too was a child sexual abuser. (See Compl. p. 11.)

Plaintiff alleges that Episode 5 falsely states and/or implies that Schneider is a convicted child molester and/or allowed them on set. (See Compl. p. 14.)

Plaintiff alleges that the Trailer and Quiet on Set, as set forth above, knowingly and intentionally go out of their way to state or implicate that Schneider sexually abused children on his shows, committed crimes, and is the same as or equivalent to convicted child molesters. (Compl. ¶ 47.)

SPECIAL MOTION TO STRIKE
A cause of action against a person arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue shall be subject to a special motion to strike, unless the court determines that the plaintiff has established that there is a probability that the plaintiff will prevail on the claim. (CCP § 425.16(b)(1).)

Consideration of a section 425.16 motion to strike involves a two-step process. “First, the court decides whether the defendant has made a threshold showing that the challenged cause of action is one arising from protected activity. The moving defendant’s burden is to demonstrate that the act or acts of which the plaintiff complains were taken ‘in furtherance of the [defendant]’s right of petition or free speech under the Unites States or California Constitution in connection with a public issue,’ as defined in the statutes. (§425.16 subd. (b)(1). If the court finds such a showing has been made, it then determines whether the plaintiff has demonstrated a probability of prevailing on the claim.” (Equilon Enterprises, LLC v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 67.)

ANALYSIS
Defamation Per Se Under Civ. Code §§ 44-46 and California Common Law

First Prong
“[A] special motion to strike under section 425.16 involves a two-step process. First, the moving defendant must make a prima facie showing ‘that the act or acts of which the plaintiff complains were taken “in furtherance of the [defendant]’s right of petition or free speech . . . .’” [Citation.]” (City of Montebello v. Vasquez (2016) 1 Cal.5th 409, 420.) If the defendant carries this burden, the plaintiff must then demonstrate its claims have at least “‘minimal merit.’” (Baral v. Schnitt (2016) 1 Cal.5th 376, 384-385.)

 

Under CCP §425.16(e), an act in furtherance of a person’s right of petition or free speech under the United States or California Constitution in connection with a public issue includes:

(1) any written or oral statement or writing made before a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law,

(2) any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law,

(3) any written or oral statement or writing made in a place open to the public or a public forum in connection with an issue of public interest, or

(4) any other conduct in furtherance of the exercise of the constitutional right of petition or the constitutional right of free speech in connection with a public issue or an issue of public interest.

 

(CCP § 425.16(e).)

 

Plaintiff’s Complaint brings a cause of action for “Defamation Per Se Under Civ. Code §§ 44-46 And California Common Law.” Plaintiff’s Complaint is based on the alleged statements and implications arising from the television docuseries Quiet on Set: Dark Side of Kids TV (Quiet on Set) and the trailer for Quiet on Set.

 

Here, Defendants made a prima facie showing that the act or acts of which Plaintiff complains were taken in furtherance of the Defendants’ right of petition or free speech.

 

As Plaintiff’s Opposition to Defendants’ motion concedes:

 

Schneider does not contest step one of the anti-SLAPP analysis, which requires the defendant to establish that the challenged claim arises from activity protected by Code of Civil Procedure section 425.16. Monster Energy Co., 7 Cal. 5th at 788. Accordingly, Schneider declines to address Section IIIB of the Motion, which concerns only that first prong.

 

(Pl. Oppo. p. 3, fn. 2.)

 

Second Prong
With respect to the second prong:

 

If the defendant makes the required showing, the burden shifts to the plaintiff to demonstrate the merit of the claim by establishing a probability of success. We have described this second step as a ‘summary-judgment-like procedure.’ [Citation.] The court does not weigh evidence or resolve conflicting factual claims. Its inquiry is limited to whether the plaintiff has stated a legally sufficient claim and made a prima facie factual showing sufficient to sustain a favorable judgment. It accepts the plaintiff's evidence as true, and evaluates the defendant's showing only to determine if it defeats the plaintiff's claim as a matter of law. [Citation.] ‘[C]laims with the requisite minimal merit may proceed.’ ”

 

(Sweetwater Union High School Dist. v. Gilbane Building Co. (2019) 6 Cal.5th 931, 940.)

 

Here, Plaintiff did not meet his burden in establishing that his claim for defamation per se has minimal merit.

 

Plaintiff filed a cause of action labeled “Defamation Per Se Under Civ. Code §§ 44-46 and California Common Law.” This action is based on Defendants’ docuseries, Quiet on Set, and the trailer for Quiet on Set, allegedly making publicly defamatory statements and implications of fact with respect to Schneider (Plaintiff), including that Schneider committed crimes of child sexual abuse, or otherwise committed child sexual abuse, with respect to children who worked on his shows, similar or equivalent to crimes committed by named convicted child molesters. (See Compl ¶ 60.)

 

Defamation is effected by either libel or slander. (See Civil Code ¶ 44.)

 

“Libel is a false and unprivileged publication by writing, printing, picture, effigy, or other fixed representation to the eye, which exposes any person to hatred, contempt, ridicule, or obloquy, or which causes him to be shunned or avoided, or which has a tendency to injure him in his occupation.” (Civil Code § 45.)

 

Further, under Civil Code § 46:

 

Slander is a false and unprivileged publication, orally uttered, and also communications by radio or any mechanical or other means which:

 

1. Charges any person with crime, or with having been indicted, convicted, or punished for crime;

2. Imputes in him the present existence of an infectious, contagious, or loathsome disease;

3. Tends directly to injure him in respect to his office, profession, trade or business, either by imputing to him general disqualification in those respects which the office or other occupation peculiarly requires, or by imputing something with reference to his office, profession, trade, or business that has a natural tendency to lessen its profits;

4. Imputes to him impotence or a want of chastity; or

5. Which, by natural consequence, causes actual damage.

 

(Civil Code § 46.)

 

The tort of defamation involves (a) a publication that is (b) false, (c) defamatory, and (d) unprivileged, and that (e) has a natural tendency to injure or that causes special damage. (Taus v. Loftus (2007) 40 Cal.4th 683, 720.)

 

As can be seen from both the statutory and common law definitions of defamation, the alleged defamation must be false.

 

Problematic with Plaintiff’s Opposition is that Plaintiff does not come forward with any evidence that the alleged defamatory statements are false.

 

“To establish a probability of prevailing, the plaintiff must demonstrate that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts to sustain a favorable judgment if the evidence submitted by the plaintiff is credited.” (Soukup v. Law Offices of Herbert Hafif  (2006) 39 Cal.4th 260, 291.)

 

Here, Plaintiff did not even come forward with his own affidavit or declaration stating that the alleged defamatory statements and implications were false. Therefore, since Plaintiff did not come forward with evidence that the alleged statements or implications were false, Plaintiff cannot meet the prima facie showing for a cause of action for defamation because a cause of action for defamation must show that the alleged defamation was false.

 

“As to the second step inquiry, a plaintiff seeking to demonstrate the merit of the claim ‘may not rely solely on its complaint, even if verified; instead, its proof must be made upon competent admissible evidence.’” (Sweetwater Union High School Dist. v. Gilbane Building Co. (2019) 6 Cal.5th 931, 940 quoting San Diegans for Open Government v. San Diego State University Research Foundation (2017) 13 Cal.App.5th 76, 95.)

 

“Although not mentioned in the SLAPP Act, the Code of Civil Procedure also allows a court to consider, in lieu of an affidavit, certain written declarations. To qualify as an alternative to an affidavit, a declaration must be signed and recite that the person making it certifies it to be true under penalty of perjury. The document must reflect the date and place of execution, if signed in California, or recite that it is executed “under the laws of the State of California.”” (Sweetwater Union High School Dist. v. Gilbane Building Co. (2019) 6 Cal.5th 931, 941.)

 

A large portion of Plaintiff’s Opposition arguesthat defamation can be implied, that the trailer and documentary state or imply Schneider sexually abused children who worked on his show and that Schneider was a child sexual abuser, and how the ordinary viewer understands the trailer and documentary to be defamatory.

 

The Court notes that even if all of  the aforementioned arguments by Plaintiff are true, this is beside the point.

 

Plaintiff still had the burden to come forward with evidence to set forth the prima facie case for defamation. Plaintiff here did not submit any evidence as to the falsity of the alleged defamation.

 

Plaintiff came forward with the declaration of Doug Bania; however, this declaration pertains only to damages/harm to Plaintiff. This declaration did not come forward with evidence that the alleged defamation is false.

 

Plaintiff also came forward with the declaration of John Vaccaro, who is a digital media executive. This declaration also did not come forward with evidence that the alleged defamation is false.

 

Thus, Plaintiff did not show a probability that Plaintiff will prevail on the merits.

 

TENTATIVE RULING
Defendants’ motion to strike the Complaint pursuant to CCP § 425.16 is GRANTED. Plaintiff did not meet his burden in showing a probability of prevailing on the merits of the defamation cause of action.

 

Defendants’ notice page to this motion stated, “Defendants also seek an award of attorneys’ fees against Plaintiff pursuant to Cal. Civ. Proc. Code §425.16(c). Defendants will submit a supporting declaration and motion for attorneys’ fees should the instant Motion be granted.” (Def. Not. p. 3.)

 

Therefore, based on page 3 of Defendants’ notice, based on the motion not containing an argument with respect to attorneys’ fees, and based on there being no declarations with respect to attorneys’ fees, the Court will assume Defendants are not seeking attorneys’ fees at this hearing.

 

““In general, the party prevailing on a special motion to strike may seek an attorney fees award through three different avenues: simultaneously with litigating the special motion to strike, by a subsequent noticed motion, or as part of a cost memorandum at the conclusion of the litigation. [Citations.]” (Martin v. Inland Empire Utilities Agency (2011) 198 Cal.App.4th 611, 631 quoting Melbostad v. Fisher (2008) 165 Cal.App.4th 987, 992.)

 

Defendants’ requests for judicial notice with the moving papers are DENIED.

 

Plaintiff’s requests for judicial notice with the opposing papers are DENIED.

 

Defendants’ evidentiary objections to the John Vaccaro Declaration are OVERRULED.

 

Defendants’ evidentiary objections to the Doug Bania Declaration are OVERRULED.