Background
Waseem Daker, proceeding pro se, appealed the Middle District of Georgia’s dismissal of his complaint under Section nineteen hundred eighty-three of Title forty-two of the United States Code. The dismissal was based on Daker’s failure to comply with a permanent filing injunction issued by the Northern District of Georgia. Daker also challenged the denial of his motion to vacate or reconsider the dismissal under Federal Rule of Civil Procedure fifty-nine.
The court’s reasoning
The court reviewed the filing injunction de novo for abuse of discretion and the dismissal for abuse of discretion. The court distinguished the injunction at issue from the universal injunctions addressed in Trump v. CASA, noting that the filing injunction did not provide direct relief to nonparties but merely required Daker to take specified actions when filing new lawsuits. The court found that Daker violated the plain terms of the injunction and failed to make every reasonable effort to comply, even considering allegations of prison interference. The court also affirmed the rejection of the amended complaint and the denial of the Rule fifty-nine motion, as Daker failed to identify new evidence or manifest errors of law or fact.
What it means going forward
The ruling reinforces the authority of federal courts to enforce filing injunctions against serial litigants and clarifies that such targeted injunctions remain valid despite recent Supreme Court limitations on universal injunctions.
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