Waseem Daker, a pro se prisoner, filed a lawsuit under 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act (RLUIPA) in the Southern District of Georgia against former Georgia Department of Corrections officials. The case was dismissed by the district court because Daker failed to comply with a filing injunction issued by the Northern District of Georgia. This injunction was designed to restrict access to the federal courts for Daker due to his history of vexatious and abusive litigation. Daker appealed, arguing that the injunction was invalid and that the dismissal was procedurally improper.
The Eleventh Circuit reviewed the district court's dismissal for abuse of discretion. First, the court addressed Daker's claim that the filing injunction was an impermissible universal or nationwide injunction under Trump v. CASA, Inc. The court clarified that while the Supreme Court in CASA barred universal injunctions that prohibit the government from enforcing laws against anyone anywhere, the order in this case was limited specifically to Daker as a party in the litigation. Because the order did not prohibit the government from enforcing laws against the general public, it was not a universal injunction and remained valid under the Judiciary Act. Second, the court rejected the argument that the warning of dismissal only applied to the Northern District, noting that a prior unpublished opinion in this same case had already established that the order applied outside that district. Third, regarding the amended complaint, the court found that Daker failed to comply with the order by omitting required documents and that his filing was untimely under Federal Rule of Civil Procedure 15(a)(1). The court also determined that Daker's litigiousness indicated a lack of good faith. Fourth, the court clarified that the standard of accepting allegations as true applies to failure to state a claim, not to failure to comply with a court order. Fifth, the court rejected the argument that Perttu v. Richards required a jury trial on court-access claims, explaining that Perttu applies to exhaustion issues intertwined with the merits, whereas this dismissal was based on non-compliance with a court order. Finally, the court upheld the dismissal with prejudice, finding that the district court implicitly made the required findings that Daker engaged in contumacious conduct and that lesser sanctions would not suffice.
The decision reinforces the authority of federal district courts to issue specific filing injunctions against individual litigants who abuse the judicial process, even when those orders have effects beyond the immediate district. It clarifies that such targeted orders are not barred by the Supreme Court's prohibition on universal injunctions. The case is remanded to the district court with instructions to maintain the dismissal, effectively barring Daker from proceeding with this specific litigation unless he can demonstrate compliance with the filing order or a modification of the injunction.
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