Actor’s Lawsuit Against Scientology Church Survives Scrutiny

Monday, August 3, 2026

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Court of Appeal:

Actor’s Lawsuit Against Scientology Church Survives Scrutiny

Opinion Says Some Defamation, Other Claims Asserted by Leah Remini, Who Alleges That She Was Targeted in Harassment Campaign After Leaving Group, Have Sufficient Minimal Merit to Withstand Anti-SLAPP Motion

By Kimber Cooley, associate editor

LEAH REMINI
actress

Div. Two of this district’s Court of Appeal on Friday held that some of Emmy Award-winning actress Leah Remini’s claims against the Church of Scientology International, over an alleged campaign of harassment initiated against her after she chose to speak out about what she says are abuses within the organization, survive anti-SLAPP scrutiny, affirming and reversing in part a trial court ruling coming to the same conclusion.

Presiding Justice Elwood Lui authored the unpublished opinion, joined in by Justices Anne Richardson and Stephen Goorvitch, which revives certain allegations relating to Remini’s claim that the organization publicly defamed her that were ordered specially stricken as time-barred, such as allegations that she “is a liar,” “would not help to pay for [her father’s] cancer treatments,” and that she “ransacked her dying grandmother’s apartment.”

Saying that although those statements were initially published outside the one-year statute of limitations, Lui found that the defendants republished them on social media within the allowable time frame. He further directed the trial court on remand to grant the defendant’s motion as to “additional nonactionable and/or unsubstantiated allegations.”

Lui added that other claims, such as causes of action for intentional infliction of emotional damage and tortious interference with contractual relationships, which survived the motion at the trial court level, “are supported by other conduct not challenged on appeal.”

Complaint Filed

Remini filed a complaint against the Church of Scientology (“CSI”) and a purportedly related entity, Religious Technology Center (“RTC”), in August 2023, alleging that the defendants “have undertaken a campaign to ruin and destroy [her] life and livelihood.” She asserted that she was declared a “suppressive person” by the organization after her public departure from the group led her to become “an outspoken public advocate for victims of Scientology.”

Remini released a memoir in 2015 about her time with CSI, entitled “Troublemaker: Surviving Hollywood and Scientology,” and co-hosted the “Scientology: Fair Game” podcast with Mike Rinder, who identifies himself as a former board member of the group assigned to investigate dissenting voices, before the episodes ceased airing in 2022.

She said that the defendants “implemented a…coordinated social media effort against Ms. Remini to spread false and malicious information about her through hundreds of Scientology-run websites and social media accounts” and that the “incessant harassment of anyone…affiliated with [her] has caused [the actor] to lose…business contracts.”

The defendants responded to the complaint by jointly filing an anti-SLAPP motion under Code of Civil Procedure §425.16, which provides:

“A cause of action…arising from any act…in furtherance of the person’s right of petition or free speech…in connection with a public issue shall be subject to a special motion to strike, unless the court determines that…there is a probability that the plaintiff will prevail on the claim.”

Allegations in Complaint

CSI and RTC sought to specially strike nearly 100 allegations in the complaint as well as accompanying causes of action and attached a declaration from a CSI minister, Lynn R. Farny, who admitted:

“When someone is expelled from the religion, they are declared a Suppressive Person. Church doctrine with respect to such people is that neither the Church nor individual Scientologists will have anything to do with them….”

In opposing the motion, Remini submitted two declarations, one in which she averred to the falsity of the challenged allegations and another signed by Rinder, who attested that the group uses tactics such as false accusations of criminal activity and online harassment to intimate so-called “suppressive persons.”

Los Angeles Superior Court Judge Randolph Hammock noted that the multitude of claims “were hard to keep track of” as they were pleaded in a “shotgun” style but scrutinized each of the allegations at issue in the motion. At the first step of the anti-SLAPP analysis, he found that the bulk of the allegations identified in the request amounted to protected speech.

As to the plaintiff’s probability of prevailing on her causes of action, Hammock specially struck about half of the nearly 100 allegations at issue, finding that they were either barred by the statute of limitations or were not actionable because they involved opinions or vague statements. As to remaining assertions, he found that the plaintiff met her burden as a “public figure” to show that the allegedly defamatory statements were made with actual malice.

Both parties appealed.

Met Their Burden

Lui wrote:

“The trial court did not err in finding that Defendants met their burden of making a prima facie showing that the statements and conduct at issue in these allegations were protected under the anti SLAPP statute….Defendants’ alleged online statements were made ‘in a place open to the public or a public forum’ within the meaning of section 425.16, subdivision (e)(3)….And, as asserted by Defendants, their communications with advertisers and producers sufficiently met the standard of ‘conduct in furtherance of the exercise of the constitutional right of petition or the constitutional right of free speech’ under section 425.16, subdivision (e)(4).”

Rejecting Remini’s assertion that the defendants failed to demonstrate that the statements were sufficiently “public,” he added:

“Remini actively participated in making her dispute with Scientology into a matter of public concern, through her book, television show, and podcast. Given this background, the parties’ trading of insults itself implicated a public issue.”

Turning to the challenged allegations, he wrote:

“[M]ost of the allegations relate primarily to Remini’s defamation cause of action, which requires a defendant’s ‘intentional publication of a statement of fact that is false, unprivileged, and has a natural tendency to injure or that causes special damage.’…California has adopted the common law rule that ‘one who republishes a defamatory statement is deemed thereby to have adopted it and so may be held liable….’ ”

Republication of Assertions

Finding that the assertions that the defendants republished the assertions that she “is a liar,” “would not help to pay for [her father’s] cancer treatments,” and that she “ransacked her dying grandmother’s apartment” within the statutory window, he further declared that each of the three statements are “actionable” under defamation principles.

As to actual malice, he said:

“Remini’s evidence tends to demonstrate an established pattern and practice of deliberate attacks by Defendants (and those directed by Defendants) intended to sully the reputations of perceived opponents, which includes the dissemination of defamatory statements. Remini presents evidence that she was deemed a suppressive person, and that she was accordingly targeted. She makes a prima facie showing that Defendants, at a minimum, acted with reckless disregard in publishing statements about which they harbored serious doubts, which Remini has sufficiently shown were false. Indeed, a reasonable inference is that Defendants intentionally published false statements about Remini because of their hostility toward her.”

The case is Remini v. Church of Scientology International, B337765.

Daniel A. Saunders and Amit R. Vora of Kasowitz Benson Torres acted for Remini.

Scott P. Dixler, Jasjaap S. Sidhu, and Jeremy B. Rosen of Horvitz & Levy as well as William H. Forman, Margaret E. Dayton and Jeffrey L. Steinfeld of Winston & Strawn represented CSI. Robert E. Mangels and Matthew D. Hinks of Jeffer Mangels Butler & Mitchell acted for RTC.