Huang v. Hanks, 232 Cal. Rptr. 3d 609

Pro se appellant filed 31 civil harassment restraining order petitions against numerous public figures, alleging fantastical conspiracies involving mind-reading "nano probes," stalking, sexual assaults, and physical attacks.
Trial court characterized the petitions as "patently frivolous" and denied the requests for permanent harassment injunctions with prejudice.
Appellant appealed the 31 denials; the appeals were consolidated for disposition in the Court of Appeal.
The clerk's transcripts on appeal contained only the pleadings, minute orders, and notices of appeal; no reporter's transcript or offers of proof were provided by appellant.
The Court of Appeal reviewed whether the trial court properly dismissed frivolous pleadings under its inherent authority and whether any preserved record showed reversible error on due process, interpreter performance, or judicial bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court properly dismissed petitions as frivolous	Appellant contends petitions should not have been dismissed; sought to present evidence	Trial court treated pleadings as patently frivolous and dismissed to prevent misuse of process	Affirmed: pleadings were frivolous; inherent authority supports dismissal
Whether denial prevented appellant from presenting evidence	Appellant says court refused to let him present evidence	No reporter's transcript or offers of proof in record to show what evidence would cure pleadings	Affirmed: insufficient record to show denial of opportunity to present evidence
Whether interpreter was unprofessional and interfered with proceedings	Appellant claims interpreter interrupted and was not professional	Clerk's record contains no evidence of interpreter failure or resulting prejudice	Affirmed: no record-based showing of interpreter incompetence or prejudice
Whether trial judge was biased	Appellant alleges judge partisan for Clinton and biased against him	Allegations are unverified, conclusory, and primarily complaints about rulings; no record support	Affirmed: judicial-bias claim not established on record; rulings alone insufficient

Vidrio v. Hernandez, 172 Cal.App.4th 1443 (court inherent power to control proceedings)
Stephen Slesinger, Inc. v. Walt Disney Co., 155 Cal.App.4th 736 (inherent authority to protect parties from frivolous litigation)
Ferguson v. Keays, 4 Cal.3d 649 (appellate inherent power to dismiss frivolous appeals)
In re Marriage of Flaherty, 31 Cal.3d 637 (definition of indisputably meritless appeals)
Denton v. Hernandez, 504 U.S. 25 (frivolous pleadings include fantastic or delusional scenarios)
Neitzke v. Williams, 490 U.S. 319 (examples of pleadings lacking arguable basis in fact)
Ballard v. Uribe, 41 Cal.3d 564 (appellant bears burden to show reversible error by adequate record)
Krueger v. Bank of America, 145 Cal.App.3d 204 (appeal on judgment roll where no reporter's transcript)
Allen v. Toten, 172 Cal.App.3d 1079 (review confined to sufficiency of pleadings when record is limited)