Background
Angela DeBose, a licensed attorney proceeding pro se, appealed the denial of her motion to dissolve a limited filing injunction. The injunction, imposed in two thousand and twenty-two, barred her from filing further lawsuits about her employment at the University of South Florida without an attorney barred in Florida or the Middle District of Florida. The Eleventh Circuit had previously affirmed the imposition of this injunction in two thousand and twenty-four.
The court’s reasoning
District courts have inherent power to protect their jurisdiction from conduct impairing their Article III functions. Federal Rule of Civil Procedure sixty-one B five permits relief if applying the order prospectively is no longer equitable due to a significant change in factual conditions or law. The party seeking relief bears the burden of establishing such a change. DeBose failed to meet this burden because the injunction was imposed due to her filing duplicitous lawsuits, not because of professional misconduct. Therefore, a letter from the Wisconsin Office of Lawyer Regulation clearing her of misconduct was immaterial to the injunction’s aims.
What it means going forward
The ruling reinforces that limited filing injunctions targeting vexatious litigation remain enforceable even if a litigant is later cleared of unrelated professional misconduct charges.