Libel Litigation in … Disneyland Social Clubs

Banal law, but fun facts.

|The Volokh Conspiracy |


Yesterday's California Court of Appeal Sarno v. Bailes decision strikes me as a pretty routine libel, invasion of privacy, and anti-SLAPP case—except for the background:

Disneyland enthusiasts created unincorporated associations to socialize with each other in the park.  The social clubs were named for a Disney character or theme, and in the park, members wear clothing, etc., identifying their club.  The social clubs maintain Web pages on social media platforms.  Two of the social clubs are "The Main St. Fire 55 Social Club" (MSF) and the "White Rabbits Social Club" (WR).

Also relevant, "the social club 'The Mermaids,'" and a 12-year-old daughter of a Mermaids member who is charmingly referred to as Little Doe (Bambi's sister, maybe?). Unfortunately, things turn far less happiest-place-on-Earth from there; the opinion offers all the grim details.