Marilyn Manson Loses Bid to Keep Defamation Claims Against Evan Rachel Wood

Winston Cho
·4 min read
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Evan Rachel Wood will not have to face defamation claims from Marilyn Manson accusing her of manufacturing a conspiracy to portray him as a serial abuser who has sexually assaulted several women.

At the center of the dispute were allegations that Wood and her friend Illma Gore lied to prospective accusers to encourage them to come forward with sexual assault allegations against the musician, namely by saying that he filmed the assault of a minor in a 1996 short film he made called Groupie. In a tentative ruling adopted by the court on Tuesday, Los Angeles Superior Court Judge Teresa Beaudet tossed claims against Wood under a law providing for the dismissal of suits arising out of protected speech.

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Manson, whose real name is Brian Warner, sued the pair in 2021 ahead of the premiere of HBO documentary Phoenix Rising, which explores sexual assault allegations against the musician and Wood’s efforts to pass legislation that extends the statute of limitations for domestic violence cases in California. He alleged that they recruited and pressured women to simultaneously emerge with allegations of rape and abuse against Warner to boost Wood’s career. To convince the accusers, Gore told them that the actress in Groupie was a minor at the time of the shoot, was dead and that Warner would be indicted if the video was released, according to the complaint.

In his suit, Warner didn’t allege that Wood made false statements about Groupie but that she “condoned and encouraged Gore” to do so. He argued that Wood should’ve told Gore that the actress in the film, whose identity remains unknown, was of age. Wood countered that failing to correct a statement doesn’t rise to a conspiracy to defame, especially in the absence of evidence that she knew the statement was false.

Beaudet sided with the defense that Warner would likely not be able to win on his defamation claims. She concluded that Warner didn’t prove that Wood agreed with Gore’s allegedly defamatory statements, or that she was aware that Gore planned to defame the musician.

“The Court does not find that Plaintiff has demonstrated that Wood had ‘concurred’ in Gore’s alleged defamatory statements about ‘Groupie’ with knowledge of their unlawful purpose, or that Wood intended to aid in achieving Gore’s objective of making such alleged defamatory statements,” reads the ruling.

To prove defamation, Warner had to offer proof that the defendants acted with “actual malice” — meaning that they either knew the statements were false or acted with reckless disregard for the truth.

The judge similarly dismissed the defamation claim against Gore, pointing to a lack of evidence that she understood the Groupie actress to be an adult, but said otherwise.

Warner argued that Gore never personally saw the film. While she conceded that point in her deposition, Gore denied having told others that the movie included an underage actress in a sex scene and stressed that Warner stated in interviews that he could be prosecuted if it was released. She also testified that she believed Jeanette Polard was the actress in the film based on conversations with a person who called her claiming to be Polard’s relative. Another actress came forward in a court declaration that she was in the movie when she was roughly 22 years old, but Warner didn’t offer proof that Polard wasn’t also in the movie, the judge said.

Polard was a fan of Manson and was known for carving his name into her chest before shows. She killed herself in 2006, according to a blog post from her sister.

Howard King, Warner’s lawyer, said he will appeal the ruling. “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.”

Michael Kump, Wood’s lawyer, said the ruling “affirms and protects Evan’s exercise of her fundamental First Amendment rights.” He added, “As the Court correctly found, Plaintiff failed to show that his claims against her have even minimal merit.”

There are still claims for hacking and wrongful impersonation based on allegations that Wood and Gore impersonated a federal agent by forging a letter claiming that his accusers were in danger.

The Westworld actress, who was in a relationship with Manson from 2006 to 2010, is one of several people to accuse the musician of assault and abuse. Others include Game of Thrones actress Esme Bianco and ex-girlfriend Ashley Morgan Smithline. Bianco settled her suit while Smithline recanted her allegations against the musician after stating in a court declaration that she was “manipulated” by Wood.

Manson, who’s been dropped by his record label Loma Vista and Creative Artists Agency, has denied all of the allegations.

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