Marriage of Deal

BACKGROUND

Patricia and Thomas married in 1989 and had twins in 1996. In 2001, Patricia petitioned to dissolve the marriage. A judgment dissolving the marriage was entered the following year. Thereafter, Thomas began representing himself. In 2005, the trial court deemed Thomas a vexatious litigant and issued a prefiling order prohibiting him from filing new motions or litigation when representing himself without first obtaining leave of the presiding judge of the court where the litigation was proposed to be filed. (Deal, supra, 45 Cal.App.5th at p. 615.) In 2008, the court entered judgment on reserved issues. (Ibid.) In 2018, the trial court reaffirmed its previous finding that Thomas is a vexatious litigant, and it again imposed a prefiling order. (Deal, supra, 45 Cal.App.5th at p. 616.) Representing himself, Thomas appealed. His briefs contained “menacing” and “odious” language making “implicit threats against various members of the California judiciary and State Bar.” (Id. at pp. 616–617.) In addition to arguing the vexatious litigant and prefiling orders were void and unsupported by substantial evidence, Thomas challenged trial court orders and appellate court rulings made…