MAPES v. CARROLL COUNTY INDIANA (2026)

Published Order Imposing Communication Restrictions

Three years ago, we cautioned Appellant—who, at that time, had initiated ten appeals—that continuing his abusive litigation practices and misuse of Clerk resources “will likely result in the Court restricting his filings and his communications with Clerk personnel.” Mapes v. State, 201 N.E.3d 1168 (Ind. 2023). On July 17, 2025, the Court of Appeals issued an order in this matter restricting Appellant's ability to file new documents and communicate with the Appellate Clerk. The Court of Appeals found that Appellant—who, as of the date of this order, has initiated eighteen appeals—“is a prolific, abusive litigant whose numerous filings have been a drain on judicial resources.”

Instead of heeding this Court's caution in Mapes v. State in 2023, and instead of complying with the Court of Appeals’ July 2025 order, Appellant continued to call the Clerk's office hundreds of times between August and December 2025. In many of these calls, he was profane and verbally abusive toward staff. And so on December 19, 2025, we issued an order requiring Appellant to show cause in writing, within ten days, why the Court should not impose its own filing and communication restrictions consistent with those imposed by the Court of Appeals in its July 17, 2025 order. Appellant did not file a written response to show cause.

Being duly advised, the Court ORDERS the following conditions and restrictions:

1. With regard to any future appeals initiated by Appellant, this Court finds Appellant's propensity toward endless litigation warrants the unusual step of establishing a screening mechanism to forestall future frivolous lawsuits. See Atkins v. Holzbog, 203 N.E.3d 1052, 1054 (Ind. Ct. App. 2023).

2. Accordingly, the Court imposes the following restrictions on Appellant:

a. Any Notice of Appeal Appellant files must fully comply with the content requirements of Appellate Rule 9(F) and Form #App.R. 9-1. If it does not, then the Clerk is directed to return the Notice of Appeal to Appellant without docketing it.

b. At the time Appellant tenders a Notice of Appeal, he must either pay the appellate filing fee as required by Appellate Rule 9(E) or comply with Appellate Rule 40 by showing that he has been granted permission by the trial court to proceed on appeal in forma pauperis. If Appellant does not pay the appellate filing fee or comply with Appellate Rule 40, then the Clerk is directed to return the Notice of Appeal to Appellant without docketing it.

c. Any documents tendered by Appellant in a case after the Notice of Appeal has been filed must fully comply with the Rules of Appellate Procedure. If the tendered document does not fully comply with the Rules of Appellate Procedure, then the Clerk is directed to return the noncompliant document to Appellant without docketing it.

d. Appellant must include a copy of this order with all documents he tenders with the Appellate Clerk. If Appellant does not do so, then the Clerk is directed to return the document to Appellant without docketing it.

3. Because of his continuing abusive interactions with personnel in the Appellate Clerk's office, Appellant may communicate with the Clerk's office only in writing. Appellant is prohibited from contacting the Clerk's office by phone.

All Justices concur except Rush, C.J., who did not participate in the decision of this matter.