John v. Super. Ct.

Summary

The California Supreme Court held that the vexatious-litigant prefiling requirements do not apply to a self-represented defendant who appeals an adverse judgment or interlocutory order in litigation initiated by someone else. The statutory text, the Legislature's continued distinction between plaintiffs and defendants, and the legislative history of the 2011 amendment showed that the prefiling restriction targets self-represented plaintiffs, not defendants pursuing appellate review. The court affirmed the Court of Appeal's order permitting the appeal to proceed.