Arthur Lopez v. HSBC Bank USA, N.A.

CourtDistrict Court, C.D. California
DecidedJanuary 17, 2020
Docket8:19-cv-01816
StatusUnknown

This text of Arthur Lopez v. HSBC Bank USA, N.A. (Arthur Lopez v. HSBC Bank USA, N.A.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arthur Lopez v. HSBC Bank USA, N.A., (C.D. Cal. 2020).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 8:19-cv-01816-JFW-KESx Date: January 17, 2020

Title: ARTHUR LOPEZ v. HSBC BANK USA, N.A., et al.

PRESENT:

THE HONORABLE KAREN E. SCOTT, U.S. MAGISTRATE JUDGE

Jazmin Dorado Not Present Courtroom Clerk Court Reporter

ATTORNEYS PRESENT FOR ATTORNEYS PRESENT FOR PLAINTIFF: DEFENDANT: None Present None Present

PROCEEDINGS (IN CHAMBERS): Order to Show Cause Why Arthur Lopez Should Not Be Declared a Vexatious Litigant

I. LEGAL STANDARD The All Writs Act, coupled with federal courts “inherent power” to “regulate the activities of abusive litigants,” authorizes district courts to enter pre-filing orders limiting the right of vexatious litigants to file legal actions. De Long v. Hennessey, 912 F.2d 1144, 1147 (9th Cir. 1990). Thus, this authority exists independently of the Court’s subject matter jurisdiction to decide the merits of the underlying claims. See id. at 1146-47; see also Peabody v. United States, 263 F. App’x 560 (9th Cir. 2008) (affirming vexatious litigant order entered after complaint was dismissed for lack of subject matter jurisdiction). While courts’ authority to enter such orders should be exercised “rarely,” “[f]lagrant abuse of the judicial process cannot be tolerated because it enables one person to preempt the use of judicial time that properly could be used to consider the meritorious claims of other litigants.” De Long, 912 F.2d at 1148. The Ninth Circuit requires four factors (“the De Long factors”) be proven before a litigant may be declared vexatious: (1) he/she must be given adequate notice and a chance to oppose a restrictive pre-filing order before it is entered; (2) the district court must present an adequate record for review by listing the case filings that support its order; (3) the district court must further make substantive findings as to the frivolous nature of the filings; and CIVIL MINUTES – GENERAL

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(4) the order must be narrowly tailored to remedy only the litigant’s particular abuses. Id. at 1147-49. In considering whether De Long factors three and four are met, the Ninth Circuit has also directed district courts to consider:  “the litigant’s history of litigation and in particular whether it entailed vexatious, harassing or duplicative lawsuits”;  “the litigant’s motive in pursuing the litigation, e.g., does the litigant have an objective good faith expectation of prevailing?”;  “whether the litigant is represented by counsel”;  “whether the litigant has caused needless expense to other parties or has posed an unnecessary burden on the courts and their personnel”; and  “whether other sanctions would be adequate to protect the courts and other parties.” Ringgold-Lockhart v. Cty. of Los Angeles, 761 F.3d 1057, 1062 (9th Cir. 2014) (quoting Safir v. U.S. Lines, Inc., 792 F.2d 19 (2d Cir. 1986)); see also Molski v. Evergreen Dynasty Corp., 500 F.3d 1047, 1056-62 (9th Cir. 2007) (noting that Safir “provides a helpful framework for applying the two substantive factors (factors three and four) of [the De Long] standard”). “To decide whether the litigant’s [prior] actions are frivolous or harassing,” under the third factor from De Long, “the district court must look at both the number and content of the filings as indicia of the frivolousness of the litigant’s claims. … An injunction cannot issue merely upon a showing of litigiousness. The plaintiff’s claims must not only be numerous, but also be patently without merit.” Molski, 500 F.3d at 1059 (citation and quotation marks omitted). “Frivolous litigation is not limited to cases in which a legal claim is entirely without merit. It is also frivolous for a claimant who has some measure of a legitimate claim to … assert[] facts that are grossly exaggerated or totally false.” Id. at 1060-61. Claims might also be deemed vexatious if the plaintiff “repeatedly assert[s] the same claims in a slightly altered guise,” “use[s] the courts to block and hinder various business transactions of the defendants,” and/or uses “senseless and unduly burdensome” litigation tactics. Safir, 792 F.2d at 24. It appears that a vexatious litigant order need not rely only on prior lawsuits that were expressly dismissed as frivolous. For example, in Molski, the Ninth Circuit upheld a vexatious litigant order that was based on a finding that the litigant had “harassed defendants into cash settlements….” 500 F.3d at 1059-60; see also id. at 1052 (noting that “Molski had tried on the merits only one of his approximately 400 suits and had settled all the others”). Additionally, the Central District of California’s Local Rules provide in relevant part: CIVIL MINUTES – GENERAL

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On its own motion or on motion of a party, after opportunity to be heard, the Court may, at any time, order a party to give security in such amount as the Court determines to be appropriate to secure the payment of any costs, sanctions or other amounts which may be awarded against a vexatious litigant, and may make such other orders as are appropriate to control the conduct of a vexatious litigant. Such orders may include, without limitation, a directive to the Clerk not to accept further filings from the litigant without payment of normal filing fees and/or without written authorization from a judge of the Court or a Magistrate Judge, issued upon such showing of the evidence supporting the claim as the judge may require. … Any [such] order … shall be based on a finding that the litigant to whom the order is issued has abused the Court’s process and is likely to continue such abuse, unless protective measures are taken. Local Rules 83-8.2, 83-8.3. II. DISCUSSION A. Notice and a Chance to Respond Regarding De Long factor one, responding to this Order to Show Cause (“OSC”) is Mr. Lopez’s opportunity to be heard and oppose entry of a restrictive, pre-filing order. B. Frivolous Nature of the Prior Actions Regarding De Long factors two and three, the following filings by Mr. Lopez in this Court appear to be frivolous and/or abusive: Case No. Title Summary of Allegations Disposition 1 13-0897 Lopez v. In June 2012, a private In forma pauperis (“IFP”) Our Lady school did not admit his application was denied and Queen of children because of action dismissed because a Angels discrimination on the basis non-attorney guardian for Catholic of sex, religion, race, and minors must have counsel School disability, as well as in under Local Rule 83-2.2.1. retaliation in violation of the First Amendment. Lopez admitted that the school cited class size and his CIVIL MINUTES – GENERAL

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failure to timely pay tuition as reasons for the non- admission. 2 13-1445 Lopez v. During the 2012-13 school IFP was denied based on an Newport year, public school staff, inadequate showing of Elementary PTA members, and “local indigency. School real estate agencies with … ties to” the school discriminated against Lopez and his family on the basis of sex, race, and religion in various ways, e.g., disciplining Lopez’s son; failing to comply with a doctor’s note about his son; acting “hostile” towards Lopez; failing to hire any full-time male teachers; and choosing not to rent property to Lopez’s family. 3 13-1800 Lopez v. Same allegations as in case Action was dismissed for Newport no. 13-1445, realleged in a lack of prosecution after Elementary new action where Lopez about 9 months passed School paid the filing fee.

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Related

Molski v. Evergreen Dynasty Corp.
500 F.3d 1047 (Ninth Circuit, 2007)
Justin Ringgold-Lockhart v. County of Los Angeles
761 F.3d 1057 (Ninth Circuit, 2014)
Peabody v. United States
263 F. App'x 560 (Ninth Circuit, 2008)
Endsley v. California ex rel. Brown
627 F. App'x 644 (Ninth Circuit, 2015)
De Long v. Hennessey
912 F.2d 1144 (Ninth Circuit, 1990)

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Bluebook (online)
Arthur Lopez v. HSBC Bank USA, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/arthur-lopez-v-hsbc-bank-usa-na-cacd-2020.