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==History of legislation against vexatious litigation== The concept of vexatious litigation entered into law in 1896 with the [[Vexatious Actions Act 1896|Vexatious Actions Act]], enacted in [[England]] and soon extended to [[Scotland]] and [[Ireland]]. This was primarily a response to the actions of [[Alexander Chaffers]], a solicitor who filed numerous actions against [[Travers Twiss#Scandal|leading members]] of Victorian society.<ref>{{cite journal |author=Brian Simpson |title=The Rule of Law in International Affairs |journal=Proceedings of the British Academy |volume= 125 |date=2003 |page=222}}</ref> When costs were awarded against him, he failed to pay.<ref name = "alv">Alvin Stauber, "Litigious Paranoia: Confronting And Controlling Abusive Litigation In The United States, The United Kingdom", ''International Review of Business Research Papers'', Vol.5 No. 1 January 2009, pp.11- 27.</ref><ref>{{cite journal|first=Michael |last=Taggart |date=2004 |title=Alexander Chaffers and the Genesis of the Vexatious Actions Act 1896. |journal=The Cambridge Law Journal |volume=63 |issue=3 |page=656684 |doi=10.1017/S0008197304006713|doi-broken-date=28 December 2024 |s2cid=145410283 }}</ref> The first such law outside the British Isles, the [[Supreme Court Act, 1927]] was passed in Australia nearly thirty years later. This too was prompted by the behaviour of an individual, Rupert Millane.<ref>{{cite book |author1=Rosalind Dixon |author2=George Williams |date=2015 |title=The High Court, the Constitution and Australian Politics |url=https://books.google.com/books?id=KqewBgAAQBAJ&q=Rupert+Millane&pg=PA133 |publisher=Cambridge University Press |page=133 |isbn=9781107043664 }}</ref> The first vexatious litigant law in the United States was enacted in [[California]] in 1963. By 2007 four more US states had passed similar legislation: [[Florida]], [[Hawaii]], [[Ohio]], and [[Texas]].<ref name = "alv"/>
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