(PS) Henreid v. Haynes

CourtDistrict Court, E.D. California
DecidedMarch 18, 2025
Docket2:23-cv-02797
StatusUnknown

This text of (PS) Henreid v. Haynes ((PS) Henreid v. Haynes) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PS) Henreid v. Haynes, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 PAUL HENREID, No. 2:23-cv-2797-DJC-SCR 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 RAYMOND NEAL HAYNES, DAVID SOTELO, and RICHARD SKAGGS, 15 Defendants. 16 17 18 Plaintiff Paul Henreid is proceeding pro se in this action, which was referred to the 19 undersigned in accordance with Local Rule 302(c)(21) and 28 U.S.C. § 636(b)(1). Plaintiff is 20 effectively seeking to relitigate in federal court a defamation lawsuit that he pursued and lost in 21 state court. Pending before the undersigned is a joint motion by Defendants Richard Skaggs and 22 Raymond Haynes to dismiss this action for failure to state a claim (ECF No. 17), their joint 23 motion for $10,000 in sanctions (ECF No. 18), and Defendant Judge David Sotelo’s motion to 24 dismiss this action both for lack of subject matter jurisdiction and failure to state a claim (ECF 25 No. 19). As explained below, the undersigned recommends that the Court dismiss all causes of 26 action without leave to amend and grant the motion for sanctions in full. 27 //// 28 //// 1 BACKGROUND AND PROCEDURAL HISTORY 2 I. The Underlying Defamation Litigation in State Court 3 In 2018, Plaintiff was a member of the Oso Town Council until 20-year-old allegations of 4 criminal activity resurfaced. ECF No. 17-1 at 6. He was accused in 1999 of videotaping sexual 5 encounters with various dates via hidden camera without their knowledge while working as a 6 male dancer and attending law school in Missouri. Id. at 179. The charges were later expunged 7 pursuant to Missouri law, but Plaintiff still agreed to resign from the Council after it learned about 8 this history. Id. at 6-7. When someone applied to fill the vacancy, Skaggs—then-president of the 9 Council—sent an email to the other Council members stating that the Council would not be 10 deceived like it was with “Paul Henreid, who has a history of criminal convictions[.]” Id. at 7. 11 Based on Skaggs’ email, Plaintiff filed a lawsuit against him in Los Angeles County 12 Superior Court (“LASC”), Henreid v. Skaggs, Case No. 19STCV20592 (“Henreid I”), alleging 13 defamation per se and invasion of privacy by false light. Id. Haynes represented Skaggs in that 14 action, while Judge Sotelo, who has since retired from the LASC, presided over the jury trial. 15 ECF No. 5 (First Amended Complaint (“FAC”)) at 6. 16 Plaintiff moved for summary judgment in Henreid I to no avail. ECF No. 17-1 at 7. 17 Shortly thereafter, pursuant to a motion in limine by Skaggs, the court held that Plaintiff was 18 either a public figure or involved in a matter of public concern. Id. at 7-8. Plaintiff therefore 19 needed to prove actual malice by clear and convincing evidence to prevail on a claim for 20 defamation. Id. at 8. After a June 2021 trial, the jury found that although Skaggs had made false 21 statements, Plaintiff failed to show by clear and convincing evidence that Skaggs either knew the 22 statements were false or had serious doubts about their veracity. Id. at 10. 23 Plaintiff appealed the jury verdict by way of Henreid v. Skaggs, Case No. B314741 24 (Henreid II). ECF No. 17-1 at 10. On February 10, 2023, after Plaintiff appealed the verdict and 25 Judge Sotelo had retired, Plaintiff moved in Henreid I to strike from the record any allegations of 26 Plaintiff’s criminal conduct (collectively “Representations”). ECF No. 17-1 at 29-30. He also 27 moved to sanction Haynes and hold him in contempt for spreading the Representations via his 28 Objection to Plaintiff’s proposed Statement on Appeal, despite knowing the Representations were 1 false. Id. at 30. Plaintiff argued that although Haynes had invoked the litigation privilege in an 2 email to Plaintiff, this privilege did not apply to “premeditated, libelous, and criminal 3 misrepresentations to courts[.]” Id. at 37, 43. Haynes and Skaggs opposed the motion for 4 sanctions on April 27, 2023. Id. at 46, 51. 5 On July 10, 2023, Superior Court Judge Anne Richardson granted the motion in Henreid I 6 to strike the Representations from Haynes and Skaggs’ Objection to Plaintiff’s proposed 7 Statement on Appeal. ECF No. 21 at 42, 44. Judge Richardson also sealed any reference to the 8 Representations in the Objection, the opposition brief to Plaintiff’s motion for sanctions, and her 9 own order. Id. at 43. Citing California Rules of Court, Rule 2.550(d), she held there was “an 10 overriding interest in protecting” Plaintiff from having the erroneous Representations reproduced 11 in the public sphere. Id. Judge Richardson denied the request for sanctions, however, because 12 she found insufficient evidence that Skaggs had engaged in or agreed to any deceit or collusion. 13 Id. She also advised Plaintiff that this only extended to the trial court record, and that sealing 14 such Representations in the appellate record would require a separate motion in Henreid II. Id. 15 By then Plaintiff had already filed for sanctions in Henreid II based on the reiteration of 16 Representations in the appellate record. ECF No. 17-1 at 62-63, 82. 17 On February 16, 2024, the appellate court in Henreid II affirmed the judgment of Henreid 18 I. ECF No. 17-1 at 5, 27. Because Plaintiff did not oppose Skaggs and Haynes’ motion in limine 19 at the time, the court held Plaintiff failed to preserve any objection to Judge Sotelo’s finding that 20 the heightened standard for a public figure defamation claim applied. Id. at 15. Plaintiff also 21 failed to provide an adequate record for review of that decision. Id. at 16. The appellate court 22 also found that Plaintiff failed to show that Judge Sotelo had erred in his evidentiary rulings for 23 Henreid I. Id. at 20. 24 The court in Henreid II also denied Plaintiff’s motion for sanctions against Haynes 25 because he failed to show that Haynes’ conduct qualified for sanctions under California Rules of 26 Court, rule 8.276(a). Id. at 26. As to Plaintiff’s request to redact any reference to the 27 Representations in the appellate record, the court found that he had failed to file a properly 28 noticed motion to that effect. Id. 1 II. Allegations in the First Amended Complaint 2 Plaintiff is an attorney in good standing with the California Bar. He commenced this 3 action on December 1, 2023, by filing a complaint naming Haynes as the sole defendant. ECF 4 No. 1. The First Amended Complaint (“FAC”), filed May 13, 2024, is the operative pleading and 5 added Skaggs and Judge Sotelo as Defendants. 6 The FAC alleges that as part of Henreid I, Skaggs and Haynes “intentionally and 7 repeatedly” lied about Plaintiff having a “conviction for statutory rape, and the charges for 8 distributing child pornography and child molestation … [and] child abuse” (collectively, the 9 “Representations”). FAC at 8. Since Henreid I began, Plaintiff used judicially noticed 10 government records to establish the Representations were not true. Id. Plaintiff accuses Skaggs 11 and Haynes of intentionally discrediting and defaming Plaintiff through these knowingly false 12 assertions, including by tying them more strongly to him by using his name instead of “Plaintiff.” 13 Id. at 8-9. Skaggs and Haynes sought to use court filings to spread the Representations online, 14 insofar as searching Plaintiff’s name would yield snippets of filings that repeated the 15 Representations. Id. at 9. 16 The FAC alleges that Judge Sotelo’s decision on Plaintiff’s motion for summary judgment 17 in Henreid I, dated February 2, 2021, stated that one claim “factually involved a ‘sex crime’ with 18 a minor[.]” Id. at 23. The FAC alleges that this excerpt, once republished online, would make 19 Plaintiff look guilty of a crime even though the charges were dismissed decades ago and the case 20 was closed and confidential under Missouri law. Id. at 24-25.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bradley v. Fisher
80 U.S. 335 (Supreme Court, 1872)
Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
United States v. Ibarra
502 U.S. 1 (Supreme Court, 1991)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
544 U.S. 280 (Supreme Court, 2005)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
W. Eugene Scott v. Edward L. Kuhlmann, Etc.
746 F.2d 1377 (Ninth Circuit, 1984)
Javiad Akhtar v. J. Mesa
698 F.3d 1202 (Ninth Circuit, 2012)
Fayelynn Sams v. Yahoo! Inc.
713 F.3d 1175 (Ninth Circuit, 2013)
Albertson v. Raboff
295 P.2d 405 (California Supreme Court, 1956)
Von Saher v. Norton Simon Museum of Art at Pasadena
592 F.3d 954 (Ninth Circuit, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) Henreid v. Haynes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-henreid-v-haynes-caed-2025.