Background
Desiree Lee Saltkill, proceeding pro se, appealed the district court’s dismissal of her complaint against Cavender Toyota and Toyota Motor Credit Corporation. The district court had dismissed the suit with prejudice and without leave to amend under Federal Rule of Civil Procedure twelve point b six.
The court’s reasoning
On de novo review, the Fifth Circuit found the suit patently frivolous. The court held that Saltkill’s personally created bill of exchange was not a legitimate form of payment to satisfy her debt for the purchase of a vehicle. The court cited Ashcroft v. Iqbal and other precedents to support the dismissal.
her suit is patently frivolous
Saltkill v. Cavender Toyota, No. 25-50688 (5th Cir. Apr. 29, 2026)
What it means going forward
The dismissal stands with prejudice, and the plaintiff is on notice that future abusive filings could lead to sanctions or restrictions on her ability to file pleadings in this Court or any other court within its jurisdiction.
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