Reported / Citable
Background
Benjamin Woodhouse holds himself out as the principal of Havensight Capital LLC. Although a California attorney, the State Bar placed Woodhouse on involuntary inactive status in 2024. Beginning in 2014, Woodhouse filed a long series of lawsuits in federal court — initially against Nike alleging a trademark dispute over a soccer brand. Those suits and many subsequent ones were dismissed; Woodhouse and Havensight were declared vexatious litigants by the Central District of California and the Southern District of New York, with the latter issuing a nationwide injunction prohibiting them from filing new federal cases without pre-filing approval and posted security. Multiple federal judges referred Woodhouse to the State Bar.
In this 2025 action, Woodhouse sued the State Bar of California, Meta Platforms, Alphabet, Nike, and Warner Bros. Discovery in Los Angeles Superior Court. The trial court declared him a vexatious litigant under Code of Civil Procedure section 391 and entered pre-filing and posting-security orders. Woodhouse appealed.
The Court’s Holding
The Court of Appeal affirmed. Reviewing the substantial federal-court history and Woodhouse’s repeated filings, the court held the trial court properly found Woodhouse meets the section 391 vexatious-litigant criteria. Woodhouse’s complaint in this very case asserts facts that are, as a matter of law, delusional; the suit has no possibility of success. Combined with the long history of frivolous filings, that record amply supports the vexatious-litigant determination.
The court also affirmed the trial court’s pre-filing and security-posting orders. Code of Civil Procedure section 391.7 permits trial courts to require pre-filing approval for new self-represented suits by vexatious litigants and to require security for future actions. The Second District’s affirmance creates a meaningful limit on Woodhouse’s ability to continue filing frivolous suits in California state courts.
Key Takeaways
- Code of Civil Procedure section 391 vexatious-litigant determinations may rest on a substantial out-of-state and federal-court history of frivolous filings.
- Where the operative complaint alleges facts that are ‘delusional as a matter of law,’ a vexatious-litigant determination and pre-filing order are well supported.
- Pre-filing orders under section 391.7 are a powerful tool for managing serial vexatious litigants; they can require both court pre-approval and posted security.
- Inactive attorneys are subject to the same vexatious-litigant rules as non-attorneys; State Bar discipline does not insulate them from the section 391 framework.
- The decision provides courts with a clear template for handling well-documented vexatious litigants whose pro per filings impose disproportionate burdens.
Why It Matters
For California courts and litigants confronted with serial vexatious filers, this decision provides important guidance on the proper use of section 391 and section 391.7 tools. The Second District’s published opinion makes clear that California courts may rely on extensive out-of-state and federal-court histories of frivolous filings, and may impose meaningful pre-filing and security-posting requirements.
For defense counsel facing repeat suits from a known vexatious litigant, the case is a powerful template — including authority to seek pre-filing orders and security at the front end of new actions. For trial courts, the opinion supports active use of vexatious-litigant tools to manage court resources and protect defendants from harassing litigation. For the State Bar and disciplinary practitioners, the case is also an interesting illustration of how disciplinary status (here, involuntary inactive) interacts with the broader civil-procedure framework for managing problematic litigants.