Thursday, May 14, 2026
Page 3
Court of Appeal:
Litigation Privilege Bars Actor’s Invasion of Privacy Suit
Panel Says There’s No Liability for Revealing Criminal History of Adversaries in Land Litigation
By a MetNews Staff Writer
One-time actor Randy Quaid, a four-time Academy Award nominee, and his wife, Evi Quaid, have lost in their bid to gain reinstatement of their action for invasion of privacy, public disclosure of private facts, and conspiracy to invade privacy based on disclosures by the defendants in earlier litigation of the couple’s criminal records, with the Ninth U.S. Circuit Court of Appeals declaring that the litigation privilege precludes liability.
Randy Quaid, referred to in an adversary’s brief as “a known celebrity,” is known for his work in the 1996 movie “Independence Day” and the 1983 picture, “National Lampoon’s Vacation.” He received a Golden Globe Award for “Best Actor–Miniseries or Television Film” in connection with 1987 NBC movie, “LBJ: The Early Years.”
He and his wife fled to Canada in 2010 to avoid arrest on California warrants. They had been charged with burglary, stemming from occupying a guest house ay a vacant home in Santa Barbara they had once owned, and other offenses.
Canada granted citizenship to Evi Quaid but ordered deportation of Randy Quaid. Prior to the deportation date, they crossed the border, entering Vermont. There, a judge found that there were irregularities in California’s extradition papers and they became residents of that state.
Criminal Records
Criminal matters relating to the Quaids were brought up by plaintiffs R. Scott Turicchi and Lanette Turicchi in California proceedings to quiet title to the Santa Barbara property. The Quaids cross-complained.
After that litigation was resolved against the Quaids, they sued the Turicchis, their attorney, Craig Granet, and other private parties, as well as the County of Santa Barbara and employees of it, relating to the criminal proceedings having been brought up. District Court Judge Monica Ramirez Almadan dismissed their action with prejudice.
Affirmance came yesterday in a memorandum opinion by Circuit Judges Michelle T. Friedland, Johnnie B. Rawlinson, and Lawrence VanDyke. Addressing the action against the private parties, they wrote:
“The Quaids’ claims all stem from the defendants obtaining the Quaids’ criminal history records and disclosing those records in a judicial proceeding. The claims are based on a communicative act….And each of the defendants invoking the litigation privilege was a party to a state court proceeding and offered the Quaids’ criminal history records to support a legal theory. Thus, the litigation privilege bars the Quaids’ claims against the [private parties]….Because additional facts would not overcome this ‘absolute privilege,’ the district court did not abuse its discretion by dismissing the claims with prejudice because amendment would be futile.”
County Defendants
As to the county defendants, the judges said the action was barred for lack of compliance with the California’s Government Claims Act, saying that merely emailing county officials to express their indignation did not suffice.
On Nov. 11, 2023, it was found that “Randy Quaid and Evgenia Quaid are, in fact, vexatious litigants.” The Quaids appealed from that order, as well as one awarding attorney fees to a private party, but presented no argumentation on those matter, and the panel affirmed.
The case is Quaid v. Granet, 25-270.
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