United States Ninth Circuit
Ringgold-Lockhart v. County of Los Angeles, 11-57231
The district court's order declaring plaintiffs vexatious litigants and imposing a pre-filing order is vacated and remanded, where: 1) in light of the constitutional concerns such pre-filing orders implicate, the district court erred by relying in large part on plaintiff-attorney Nina Ringgold's motions practice over the course of just two federal lawsuits, without considering less restrictive sanctions; 2) the district court also erred by holding plaintiff Nina Ringgold's state litigation against plaintiff Justin Ringgold-Lockhart, without a record indicating that he participated in that litigation; and 3) there was an insufficiently close fit between the terms of the injunction and the problem it purported to address.
Appellate Information
- Decided 08/04/2014
- Published 08/04/2014
Judges
- BERZON
Court
- United States Ninth Circuit