Manson Accuser’s Recantation Can’t Be Used for Now in Case Against Evan Rachel Wood, Judge Says

A Los Angeles judge ruled Tuesday (Feb. 28) that Marilyn Manson‘s lawyers could not cite a recent bombshell recantation by Ashley Morgan Smithline, one of his former abuse accusers, in his ongoing defamation lawsuit against actress Evan Rachel Wood.

Last week, Smithline claimed in a court filing she had “succumbed to pressure” from Wood to make “untrue” accusations against Manson. The singer’s lawyers wanted to use that as evidence in their lawsuit against Wood, who they allege orchestrated an “organized attack” of false rape accusations against her ex-fiance Manson.

But Wood quickly fired back that she “never pressured or manipulated” Smithline. And her lawyers asked the judge to ignore the new filing, arguing that the “eleventh hour” reversal by Smithline was just a “bad-faith” effort to save Manson’s case from being dismissed.

In an order issued Tuesday obtained by Billboard, Judge Teresa A. Beaudet sided with Wood’s lawyers, refusing to allow Smithline’s statements to be admitted into the case record for now because they had been filed too late.

That means the judge won’t view those statements as evidence at a hearing next month over whether to dismiss Manson’s case or allow it to proceed toward trial. The ruling leaves open the possibility that the statement could be admitted if the case survives.

An attorney for Manson declined to comment. A rep for Wood did not return a request for comment.

Smithline and Wood are two of several women to accuse Manson of serious sexual wrongdoing over the past two years. After the Westworld star posted her allegations to Instagram in February 2021, lawsuits quickly followed from Smithline, Manson’s former assistant Ashley Walters, Game of Thrones actress Esmé Bianco and a Jane Doe accuser. Another Jane Doe case was filed last month.

Manson has denied all of the allegations, and the cases by Smithline, Walters and Bianco have since been dropped, dismissed or settled. Now, the rocker is pursuing his own defamation lawsuit, claiming that Wood and another woman, Illma Gore, had “secretly recruited, coordinated, and pressured prospective accusers to emerge simultaneously” with false accusations against him.

Last week, Smithline made her bombshell accusations about being “manipulated” by Wood in a sworn declaration submitted by Manson’s attorneys in the defamation case, stating: “I succumbed to pressure from Evan Rachel Wood and her associates to make accusations of rape and assault against Mr. Warner that were not true.”

The new claims came as Wood’s attorneys were seeking to dismiss Manson’s case by citing California’s so-called anti-SLAPP statute — a law that aims to make it easier to dismiss cases that threaten free speech. Wood’s lawyers say Manson’s case is exactly that: an effort to punish the actress after she chose to speak publicly about years of alleged abuse by a prominent musician.

“For years, plaintiff Brian Warner raped and tortured defendant Evan Rachel Wood and threatened retaliation if she told anyone about it,” her attorneys wrote. “Warner has now made good on those threats by filing the present lawsuit.”

Manson’s attorneys wanted to cite Smithline’s recantation as a reason for Beaudet to deny the anti-SLAPP motion. They argued that it was early proof that they could eventually win their case against Wood, meaning it was a legitimate lawsuit and not merely an effort to stifle her free speech.

But Wood’s lawyers said the window to file such evidence had closed more than three months prior and must be denied: “Plaintiff’s ex parte application is a bad-faith attempt to save his meritless SLAPP claim from dismissal by requesting leave to file an untimely declaration, containing provable falsehoods, made under unreliable circumstances.”

At a hearing Tuesday, the judge denied the request to admit Smithline’s declaration. As reported by Rolling Stone, the judge said at the live hearing that there “really is no explanation as to why this [declaration] is bubbling up at this time.”

A hearing is set for April 11 to consider Wood’s request to dismiss the case under the anti-SLAPP law.