Marilyn Manson faced a setback in court today in his ongoing defamation case against Evan Rachel Wood. Judge Teresa Beaudet threw out some of Manson’s claims from his original lawsuit, including his assertion that Wood “recruited, coordinated, and pressured” women to make false statements about him and another alleging that Wood forged an FBI letter.
In a statement, Manson’s attorney said they plan to appeal. A tentative trial date is set for May 1, 2024, though the appeal from Manson will likely push that date back. Several claims remain pending against Wood.
“We are very pleased with the Court’s ruling, which affirms and protects Evan’s exercise of her fundamental First Amendment rights,” Michael Kump, attorney for Evan Rachel Wood, said in a statement. “As the Court correctly found, Plaintiff failed to show that his claims against her have even minimal merit.”
“The ruling is disappointing but not unexpected,” Manson’s attorney Howard King said in a statement. “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 continued:
In the original lawsuit, Manson claimed that Wood and Gore “secretly recruited, coordinated, and pressured prospective accusers to emerge simultaneously with allegations of rape and abuse against Warner” and “provided checklists and scripts to prospective accusers, listing the specific alleged acts of abuse that they should claim against Warner.”
Manson submitted declarations from two women, who both claimed that Gore reached out with the note that they weren’t “obligated to speak” at a meeting and that there was “no pressure to be involved in any way.” Judge Beaudet wrote that the messages from Gore were “not ‘so extreme as to exceed all bounds of that usually tolerated in a civilized community.’” She also dismissed checklist images found on an iPad formerly owned by Gore stating “name,” “contact,” and “willing to testify.” Beaudet argues that the images don’t demonstrate intent to pressure anyone into making false accusations.
Regarding the allegedly forged FBI letter, Judge Beaudet points to Wood’s argument that she never published the letter—it surfaced in a California custody proceeding. “A forged letter, if it never saw the light of day, could not cause emotional distress, nor be intended to do so,” Wood’s argument reads. “Any alleged distress could only be caused (and intended) through the letter’s publication.” Beaudet concurs that Manson’s team doesn’t cite other instances where the letter was published.
Judge Beaudet also determined that Wood and Ilma Gore’s comments about Manson’s 1996 short film Groupie constituted “protected activity.” Manson also referred to Gore’s “false and defamatory statements” regarding Groupie, saying she falsely identified the actress in the film as a minor and referred to it as child pornography. Judge Beaudet agreed with Gore’s claim that protecting people from sex offenders is a matter of public interest.
