California Penal Code Section 159: "No person can be convicted of common barratry except upon proof that he has excited suits or proceedings at law in at least three instances, and with a corrupt or malicious intent to vex and annoy." Revised Code of Washington 9.12.010: "Every person who brings on his or her own behalf, or instigates, incites, or encourages another to bring, any false suit at law or in equity in any court of this state, with intent thereby to distress or harass a defendant in the suit, or who serves or sends any paper or document purporting to be or resembling a judicial process, that is not in fact a judicial process, is guilty of a misdemeanor; and in case the person offending is an attorney, he or she may, in addition thereto be disbarred from practicing law within this state."[10] Virginia laws on barratry, champerty, and maintenance were overturned by the Supreme Court of the United States in NAACP v. Button 371 U.S. 415 (1963). Vermont Statutes Title 13, § 701: "A person who is a common barrator shall be fined not more than $50.00 and become bound with sufficient surety for his or her good behavior for not less than one year."