Tom Sandoval’s reported 2024 filing against Ariana Madix was a cross-complaint in Rachel Leviss’s existing lawsuit—not the original lawsuit in the case. Sandoval alleged Madix accessed his phone and copied or distributed an intimate video of Leviss. Two days after the filing was reported, he said he intended to remove it and had not understood that he was suing Madix. A separate 2026 appellate decision concerned Madix’s anti-SLAPP motion in Leviss’s case; it did not decide whether anyone was ultimately liable.
What Sandoval’s filing alleged
The Los Angeles Times reported on July 17, 2024, that Sandoval had filed a cross-complaint the previous day. It alleged that Madix accessed his phone without permission, reviewed data that included explicit FaceTime footage of Leviss, and copied or distributed the video. Those were allegations in Sandoval’s filing, not facts established by a court.
A cross-complaint is a claim brought by a defendant against another party in an existing case. Sandoval’s filing arose in the context of Leviss’s lawsuit; it was not the complaint that began that case.
What Sandoval said about withdrawing it
On July 19, 2024, the Times reported Sandoval’s statement that he had not understood the filing as a new lawsuit against Madix and intended to remove the cross-complaint. He said, “The words ‘New Lawsuit’ or ‘Suing’ were not articulated to me.” That was his account of his understanding. The report does not establish the exact docket entry formally disposing of the cross-complaint, so his stated intent should not be treated as proof of a formal dismissal.
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How the filing fits into Leviss’s lawsuit
Leviss filed her separate lawsuit against Sandoval and Madix in Los Angeles County Superior Court on February 29, 2024. A May 24, 2024 tentative ruling listed claims including eavesdropping, revenge porn, invasion of privacy, and intentional infliction of emotional distress. These are claims Leviss pleaded, not findings that either defendant committed wrongdoing.
| Event | What it was | What it did not establish |
|---|---|---|
| February 29, 2024 | Leviss filed her lawsuit against Sandoval and Madix in Los Angeles County Superior Court. | The filing itself did not establish liability. |
| July 16, 2024, reported July 17 | Sandoval filed a cross-complaint in the context of Leviss’s case, alleging Madix accessed his phone and copied or distributed intimate footage. | The allegations were not court findings. |
| July 19, 2024 | Sandoval said he intended to remove the cross-complaint and had not understood it as suing Madix. | The Times report did not identify a formal docket entry disposing of it. |
| August 5, 2026 | The California Court of Appeal affirmed the denial of Madix’s anti-SLAPP motion in Leviss’s separate lawsuit. | The ruling was not a trial verdict on the claims or a decision on ultimate liability. |
What the 2026 anti-SLAPP decision decided
In Leviss v. Madix, appeal B340116, the California Court of Appeal considered Madix’s challenge to Leviss’s lawsuit under California’s anti-SLAPP statute, Code of Civil Procedure section 425.16. The statute first asks whether the challenged claims arise from protected speech or petitioning activity. Only if that threshold is met does the plaintiff have to show a probability of prevailing.
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The Court of Appeal held that Madix had not shown that the conduct underlying the claims at issue—alleged acquisition and distribution of the private videos—was protected activity connected to a public issue. The opinion described the recordings as involving “a private sexual act at a private residence during a private FaceTime call with Sandoval.” It reasoned that a person’s public profile does not make the intimate details in private sexual recordings a matter of public interest for this anti-SLAPP analysis.
The court also distinguished that conduct from possible claims based on Madix’s public comments about the videos, noting that statements could raise a different anti-SLAPP question. Its decision addressed whether the challenged claims could proceed past Madix’s motion—not whether the allegations were true, whether conduct was criminal, or who would prevail at trial.
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Sources
- Los Angeles Times, July 17, 2024: report on Sandoval’s cross-complaint.
- Los Angeles Times, July 19, 2024: report on Sandoval’s stated intent to remove it.
- California Court of Appeal, Leviss v. Madix, B340116, filed August 5, 2026.
- May 24, 2024 tentative ruling, Los Angeles County Superior Court case 24STCV05072.
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