(PS) McGee v. State of CA

District Court, E.D. California·Decided August 7, 2024·No. 2:24-cv-00012·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JEFFERSON A. McGEE, No. 2:24-cv-0012 TLN AC PS 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DISMISS WITH PREJUDICE AND TO 13 v. DECLARE PLAINTIFF A VEXATIOUS LITIGANT 14 THE STATE OF CALIFORNIA, et al., 15 Defendants. 16 17 Plaintiff is proceeding in this action in pro se and paid the filing fee, and the case was 18 accordingly referred to the undersigned for pretrial proceedings pursuant to Local Rule 19 302(c)(21). Defendant City of Sacramento has moved for an order declaring plaintiff a vexatious 20 litigant. ECF No. 98. Finding that plaintiff has an extensive history of frivolous and repetitive 21 litigation in this district, the undersigned ordered plaintiff to show cause as to why he should not 22 be declared a vexatious litigant and subjected to pre-filing conditions. ECF No. 197. Plaintiff was 23 advised that the contemplated vexatious litigant status would be made applicable to this case and 24 to each of plaintiff’s future lawsuits. Id. Plaintiff was directed to respond by August 2, 2024. Id. 25 Plaintiff responded to the order to show cause. ECF No. 213. All other action in this case has 26 been temporarily stayed pending the determination of plaintiff’s vexatious litigant status. 27 After a thorough review of plaintiff’s response to the order to show cause, the status of 28 this case, and plaintiff’s litigation history, the undersigned RECOMMENDS that plaintiff be 1 declared a vexatious litigant subject to prefiling conditions. The undersigned further 2 RECOMMENDS that if the recommendation is adopted, plaintiff be ordered to comply with the 3 prefiling conditions before proceeding with this case. 4 I. Overview 5 On January 2, 2024, plaintiff filed the complaint in this action and paid the filing fee. 6 ECF No. 1. As set forth more fully below, plaintiff Jefferson A. McGee is a serial litigant who 7 has received several warnings from judges of this court regarding the potential consequences of 8 bringing frivolous and repetitive lawsuits. The resource burden imposed by plaintiff’s litigation 9 history is not adequately captured by the mere number of frivolous actions he has filed, but also 10 arises from their sweeping scope. For example, in this case plaintiff has named 167 private and 11 public defendants who have each been required to respond the complaint. There are currently 27 12 motions pending in this case, 26 of which have been brought by defendants. Considering Mr. 13 McGee’s litigation history, which is detailed below, and his failure to show to show cause why 14 the court should not deem him a vexatious litigant and impose pre-filing conditions upon him 15 before he may proceed with this case or file any other lawsuits in this district, the undersigned 16 finds that plaintiff Jefferson A. McGee should be declared a vexatious litigant subject to the 17 prefiling conditions described below, and that the prefiling conditions should be applied to this 18 case before it is allowed to proceed. 19 II. Legal Standard 20 The district courts have the power under the All Writs Act, 28 U.S.C. § 1651(a), to issue 21 pre-filing orders that restrict a litigant’s ability to initiate court proceedings. De Long v. 22 Hennessey, 912 F.2d 1144, 1146 (9th Cir. 1990). “[S]uch pre-filing orders are an extreme 23 remedy that should rarely be used.” Molski v. Evergreen Dynasty Corp., 500 F.3d 1047, 1057 24 (9th Cir. 2007). However, “[f]lagrant abuse of the judicial process cannot be tolerated because it 25 enables one person to preempt the use of judicial time that properly could be used to consider the 26 meritorious claims of other litigants.” De Long, 912 F.2d at 1148. Before entering a pre-filing 27 order, the court must: (1) give the litigant notice and a chance to be heard before the order is 28 entered; (2) compile an adequate record for review; (3) make substantive findings about the 1 frivolous or harassing nature of the plaintiff’s litigation, and (4) narrowly tailor the vexatious 2 litigant order “to closely fit the specific vice encountered.” Molski, 500 F.3d at 1057. 3 The first and second factors “are procedural considerations”; the third and fourth factors 4 “are substantive considerations” that help the district court “define who is, in fact, a ‘vexatious 5 litigant’ and construct a remedy that will stop the litigant’s abusive behavior without unduly 6 infringing the litigant’s right to access the courts.” Id. at 1057-58. As to the substantive factors, 7 the Ninth Circuit has found a separate set of considerations (employed by the Second Circuit 8 Court of Appeals) provide a helpful framework. Ringgold-Lockhart v. County of Los Angeles, 9 761 F.3d 1057, 1062 (9th Cir. 2014) (citing Molski, 500 F.3d at 1058). They are: 10 (1) the litigant’s history of litigation and in particular whether it entailed vexatious, harassing or duplicative lawsuits; 11 (2) the litigant’s motive in pursuing the litigation, e.g., does the 12 litigant have an objective good faith expectation of prevailing?; 13 (3) whether the litigant is represented by counsel; 14 (4) whether the litigant has caused needless expense to other parties or has posed an unnecessary burden on the courts and their personnel; 15 and 16 (5) whether other sanctions would be adequate to protect the courts and other parties. 17 18 Molski, 500 F.3d at 1052 (quoting Safir v. U.S. Lines, Inc., 792 F.2d 19, 24 (2d Cir. 1986)). 19 Additionally, the Eastern District has adopted California’s “vexatious litigant” laws. See 20 Local Rule 151(b) (adopting Cal. Civ. Proc. Code §§ 391–391.8). These laws were “designed to 21 curb misuse of the court system by those persistent and obsessive litigants who, repeatedly 22 litigating the same issues through groundless actions, waste the time and resources of the court 23 system and other litigants.” Shalant v. Girardi, 51 Cal. 4th 1164, 1169 (2011). The vexatious– 24 litigant statute “provide[s] courts and nonvexatious litigants with two distinct and complementary 25 sets of remedies.” Id. at 1171. First, a plaintiff may be required to furnish security, meaning a 26 requirement for the litigant to “assure payment . . . of the party’s reasonable expenses, including 27 attorney’s fees . . . incurred in or in connection with a litigation instituted . . . by a vexatious 28 litigant.” Cal. Civ. Proc. Code § 391. If the plaintiff fails to furnish the security, the action will 1 be dismissed. Id. Second, the court may impose a prefiling order that prevents a plaintiff from 2 filing any new case in propria persona. Id. (citing Cal. Civ. Proc. Code § 391.7). 3 III. Analysis 4 The undersigned concludes that Mr. McGee’s litigation history demonstrates a pattern of 5 frivolous, repetitive, and harassing complaints that calls for him to be deemed a vexatious litigant. 6 See De Long, 912 F.2d at 1146. The court has considered plaintiff’s opposition and finds that he 7 does not show good cause to avoid a vexatious litigant order and that he should be subject to a 8 prefiling order. 9 A. Plaintiff’s Argument 10 Plaintiff asserts that he is not a vexatious litigant because he does not fit the definition 11 under California Code of Civil Procedure § 391(b).

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