Several jurisdictions in the United States have declared barratry (in the sense of a frivolous or harassing litigant) to be a crime as part of their tort reform efforts. For example, in the U.S. states of California, Oklahoma, Pennsylvania, Virginia, and Washington, barratry is a misdemeanor.[7][8] In Texas, barratry is a misdemeanor on the first conviction, but a felony on subsequent convictions.[9]