Gibson Dunn Secures Precedential Dismissal of Defamation Lawsuit for Warner Bros., Sony, and Documentary Filmmakers
Firm News | September 14, 2026
Gibson Dunn secured a major, precedential appellate victory on behalf of Warner Bros. Discovery, Inc., Sony Pictures, Maxine Productions, and documentary filmmakers Mary Robertson and Emma Schwartz when the California Court of Appeal reversed a trial court ruling and held that the defendants’ anti-SLAPP motion should be granted and the plaintiff’s lawsuit dismissed.
The defendants are the filmmakers and producers of Quiet on Set: The Dark Side of Kids TV, an acclaimed 2024 documentary series that explores the behind-the-scenes culture at Nickelodeon in the 1990s and early 2000s. One narrative thread of the documentary focuses on the toxic work environment created by Dan Schneider, the creator and producer of several popular Nickelodeon shows. Another narrative thread focuses on Nickelodeon’s employment of three convicted sex offenders, two of whom were arrested for sexually abusing child actors on Nickelodeon shows. After the documentary was released, Schneider sued the defendants for defamation. The premise of his lawsuit was that Quiet on Set falsely accuses him of child sexual abuse — even though the show clearly distinguishes between Schneider’s bad behavior (e.g., verbal abuse, bullying, discrimination) and the criminal acts of the child abusers.
In the trial court, before Gibson Dunn’s involvement, the defendants had filed a motion to strike the complaint under California’s anti-SLAPP statute. The trial court denied that motion. The defendants then retained Gibson Dunn to lead their interlocutory appeal from the trial court’s anti-SLAPP ruling. Partner Ted Boutrous presented oral argument to the California Court of Appeal on August 17.
On September 10, the Court issued a unanimous decision holding that Schneider had not satisfied his burden of showing a likelihood of success. Endorsing Gibson Dunn’s arguments, the Court held that Schneider’s claims must be evaluated under the standard for defamation by implication, which requires a showing that the alleged defamatory implication is a reasonable one. The Court held that Schneider could not make that showing, because “[t]he documentary clearly distinguishes between the lamentable conduct that its participants attribute to Schneider . . . and the child sexual abuse attributed to three named individuals,” and “Schneider’s attempt to find an alternative meaning than what is expressly stated in the documentary is unavailing.” The Court also rejected Schneider’s attempt to rely on a cherry-picked selection of social media comments as evidence that the alleged inference was reasonable, emphasizing that those were “not relevant” to the threshold legal question of reasonableness. The Court reversed the trial court’s order and directed the trial court to grant the defendants’ anti-SLAPP motion and dismiss Schneider’s lawsuit. Under the anti-SLAPP statute, the defendants will also be entitled to their attorneys’ fees.
The case is Schneider v. Warner Bros. Discovery, Inc., — Cal. Rptr. 3d –, 2026 WL 2664058 (Ct. App. Sept. 10, 2026).
The Gibson Dunn team representing the defendants included partners Theodore J. Boutrous, Jr. (argued), Ilissa Samplin, and Connor Sullivan and associate Zachary Freund.