After 2-Year Halt, Appeals Court Rules Madix Must Face Revenge Porn Claims

For litigators and privacy advocates, the appellate decision in Leviss v. Madix delivers a powerful precedent on the limits of anti-SLAPP motions in digital-era privacy cases. By holding that the non-consensual distribution of intimate images is not a matter of public interest, the court reinforces the legal firewall between tabloid spectacle and actionable misconduct—a critical distinction as revenge porn claims increasingly collide with First Amendment defenses.

On August 5, 2026, a California appellate court delivered a significant setback to former "Vanderpump Rules" star Ariana Madix, affirming a lower court's refusal to dismiss the revenge porn lawsuit filed by her former castmate Rachel "Raquel" Leviss under California's anti-SLAPP statute. The ruling means Leviss's claims—alleging invasion of privacy, eavesdropping, and violation of the state's revenge porn law—will proceed toward trial after being frozen for more than two years by the appeal. The decision underscores the limits of anti-SLAPP protection when the underlying conduct is itself allegedly unlawful, regardless of the surrounding celebrity drama or public curiosity.

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The dispute traces back to the "Scandoval" affair discovered in March 2023, when Madix found intimate FaceTime videos of Leviss on her then-boyfriend Tom Sandoval's phone.

The dispute traces back to the "Scandoval" affair discovered in March 2023, when Madix found intimate FaceTime videos of Leviss on her then-boyfriend Tom Sandoval's phone. In a sworn declaration, Madix acknowledged she secretly accessed Sandoval's device without his knowledge, copied the videos while in a women's bathroom stall, and sent excerpts to Leviss that same night, purportedly to confront her about the affair. The affair became a national tabloid obsession and a major storyline on Bravo's "Vanderpump Rules," but Leviss's lawsuit, filed in February 2024, focuses not on the affair itself but on the non-consensual recording and distribution of sexually explicit material. The complaint names both Madix and Sandoval as defendants, alleging Sandoval recorded the videos without Leviss's consent, and Madix illegally obtained and shared them.

At the core of the legal fight is California's anti-SLAPP law (Strategic Lawsuit Against Public Participation), which allows defendants to quickly strike lawsuits that threaten constitutionally protected speech or petitioning activity. Madix's legal team argued that her actions—sending the videos directly to Leviss as part of their personal conflict over the affair—were a matter of public interest because the relationship turmoil had already become a public spectacle. However, both the trial court in July 2024 and now the appellate court rejected that framing. The courts held that Madix's alleged obtaining and dissemination of the private videos were not activities protected by the First Amendment; they were potentially criminal acts under California's laws against non-consensual pornography (Civil Code § 1708.85) and invasion of privacy. The appellate panel's succinct ruling states that Madix "failed to meet her burden of establishing that the claims alleged against her arose from constitutionally protected activity."

This outcome highlights a crucial doctrinal boundary in anti-SLAPP jurisprudence: the shield of free speech does not extend to conduct that is independently illegal. Even if the surrounding facts are of public interest, the specific act—sending intimate images without consent—is not elevated to protected status merely because celebrities are involved. The ruling is consistent with a line of California cases where courts have denied anti-SLAPP motions in claims involving unauthorized distribution of private sexual materials, recognizing that the state's public policy strongly protects individuals' privacy and bodily autonomy. For those monitoring legal developments in the revenge porn space, the decision affirms that victims can pursue civil remedies without their claims being prematurely dismissed under free speech pretexts.