In Re Gaydos
Headline: Court bars future fee-free filings by a repeat pro se litigant, denies her requests for mandamus and to have the Supreme Court directly hear her FOIA case, and requires fees and proper filing before accepting new noncriminal petitions.
Holding:
- Stops this litigant from filing new fee-free civil petitions without paying fees and following filing rules.
- Requires payment of docketing fees and compliance before the Clerk accepts noncriminal petitions.
- Leaves prior FOIA complaint dismissed; does not rule on the FOIA’s merits.
Summary
Background
Maria L. Gaydos, a pro se litigant, asked the Court to waive filing fees and to order the District Court clerk to file a Freedom of Information Act (FOIA) suit challenging this Court’s orders in ten prior cases. She also sought to disqualify the District Court clerk and this Court’s clerk, to have summons issued, and alternatively asked this Court to take original jurisdiction over the FOIA claim. The Court noted Gaydos has been denied fee waivers ten times, filed multiple repetitive petitions, and that the District Court had already docketed and promptly dismissed her FOIA complaint.
Reasoning
The Court considered whether to grant mandamus relief, waive fees, or accept original jurisdiction. It denied her requests, gave her until December 23, 1996 to pay docketing fees and to file a petition that follows the Court’s rules, and ordered the Clerk not to accept any further noncriminal fee-waiver petitions from her unless she first pays and complies with filing requirements. The Court explained the order as a limited sanction for repetitive, frivolous filings, relying on its prior decision in Martin v. District of Columbia Court of Appeals. Because her misconduct was confined to noncriminal matters, the sanction is similarly confined.
Real world impact
The immediate effect is procedural: Gaydos must pay fees and follow formal filing rules before new noncriminal petitions will be accepted. The Court’s order does not address the merits of her FOIA claims and is focused on preventing future burdens on court resources.
Dissents or concurrances
Justice Stevens filed a brief dissent, citing earlier opinions in which he explained his disagreement with such sanctions.
Opinions in this case:
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