Case Explained: Non-Argument Calendar IVETTE T. ECHENIQUE v. HAMILTON HOSPITAL HR, N.P., Testins, Records, Adm RIVERWOODS BEHAVIORAL HOSPITAL All employees, H.R. insurances, physicians, testins therapists, drivers, nurses, screening records adm P.A., N.P HIGHLAND RIVERS BEHAVIORAL HOSPITAL AARP INSURANCE HAMILTON HOSPITAL – AMBULANCE N.P., et al USCA11 Case: 25-14222 Document: 17-1 Date Filed: 07/02/2026 Page: 1 of 8 2

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-02

Docket: 1:25-cv-00151-MLB

The eleventh-circuit affirmed the district court’s dismissal with prejudice of Ivette Echenique’s second amended complaint. The court held that the district court acted within its inherent authority to dismiss the pleading as a “shotgun” pleading and as frivolous under 28 U.S.C. § 1915(e)(2). The court applied the standard of review for abuse of discretion, noting that shotgun pleadings violate Federal Rules of Civil Procedure 8(a)(2) and 10(b) because they fail to provide defendants with adequate notice of the claims asserted against them or the factual basis for those claims. The opinion emphasized that while pro se complaints are liberally construed, litigants must still comply with procedural rules. The district court had previously provided Echenique with specific instructions to cure these defects by explaining jurisdiction, pleading claims separately, and identifying which defendant was responsible for which conduct. However, the second amended complaint remained lengthy, confusing, conclusory, and failed to connect specific facts to specific legal claims. Furthermore, the court found the allegations in the second complaint—describing fantastical scenarios involving sexual assault, stalking, and medical record interference by high-profile government officials—to be frivolous as they were without arguable merit in law or fact. The practical consequence is that Echenique’s appeal is dismissed, the district court’s order stands, and the case is closed with prejudice, meaning no further amendments to the complaint are permitted. Additionally, the court denied a separate motion filed by Echenique regarding mail interception allegations.

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