Vashisht-Rota v. Utah Attorney General

District Court, S.D. California·Decided November 27, 2024·No. 3:22-cv-00978·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 Aparna VASHISHT-ROTA, Case No.: 22-cv-0978-AGS-KSC 4 Plaintiff, ORDER IMPOSING SANCTIONS 5 v. 6 UTAH ATTORNEY GENERAL, et al., 7 Defendants. 8 Aparna VASHISHT-ROTA, Case No.: 20-cv-0967-AGS-KSC 9 Plaintiff, ORDER IMPOSING SANCTIONS, MOOTING SUMMARY JUDGMENT 10 v. MOTION (ECF 142), AND 11 HARRISBURG UNIVERSITY DISMISSING CASE 12 Defendant. 13 Aparna VASHISHT-ROTA, Case No.: 20-cv-0959-AGS-KSC 14 Plaintiff, ORDER IMPOSING SANCTIONS 15 v. 16 OTTAWA UNIVERSITY, 17 Defendant. 18 Aparna VASHISHT-ROTA, Case No.: 20-cv-0321-AGS-KSC 19 Plaintiff, ORDER IMPOSING SANCTIONS 20 v. 21 HOWELL MANAGEMENT SERVICES, 22 et al. 23 Defendants. 24 25 In four of plaintiff Dr. Aparna Vashisht-Rota’s cases, this Court ordered her to show 26 cause why she should not be sanctioned for “apparently flagrant violations of this Court’s 27 28 1 order.” (ECF 140.) Having now reviewed her responses and witnessed her continued and 2 unabated disobedience, it’s clear that the violations were willful, intentional, and done in 3 bad faith. Despite her pro se status, the Court’s patience with Vashisht-Rota must at last 4 draw to a close, and a sanction must be levied. In the end, the only sanction the Court can 5 conceive that will address the ongoing and rampant violations is the dismissal of Vashisht- 6 Rota’s one remaining case. 7 BACKGROUND 8 This Court’s local rules require litigants to “refrain from writing letters to the judge” 9 and mandate that “[a]ll matters to be called to a judge’s attention should be formally 10 submitted.” CivLR 83.9. To put it mildly, Vashisht-Rota has routinely ignored this 11 restriction. After one particularly bad week in February 2024, wherein she sent “over 12 40 emails” on topics ranging “from criticizing other judges, to legal arguments and 13 theories, to damages calculations, to the British royals, and even to pop star Taylor Swift’s 14 age,” the Court ordered her “to cease cc’ing the Court on communications with opposing 15 counsel and to cease emailing the Court anything other than a request for procedural help 16 in filing an upcoming motion.” (ECF 87.) This admonishment was needed because the 17 Court was wasting “hours a week skimming her emails for appropriate requests.” (Id.) Less 18 than two weeks later, the assigned magistrate judge again rebuked Vashisht-Rota for her 19 misuse of the court’s email, warning that Vashisht-Rota “must not send any other emails” 20 to that chambers “except as permitted under Magistrate Judge Crawford’s Civil Chambers 21 Rules.” (ECF 91.) 22 Yet Vashisht-Rota soon returned to her abuse of the Court’s resources. So, in 23 May 2024, this Court further restricted her communications in both quantity and substance: 24 Plaintiff is henceforth limited to contacting this Court no more than once per day, unless otherwise ordered. The term “contacting” includes emailing, 25 writing, phone-calling, leaving a voicemail, and all other forms of 26 27 1 To avoid duplication, the Court will default to citing the Harrisburg action, as it is 28 the sole remaining open case. 1 communication. In addition, although plaintiff has several cases she may want to contact the Court about, she is limited to one contact with chambers per day 2 to discuss any and all cases. Finally, any such contact or communication must 3 strictly confine itself to requesting a hearing date for an authorized motion. For all other procedural questions, plaintiff is directed to contact the 4 Clerk’s office, not chambers. 5 (ECF 100.) 6 Vashisht-Rota was undeterred. In the very next filing in the Harrisburg case, the 7 magistrate judge again “received multiple emails from plaintiff in violation of the Court’s 8 Local Rules and Chambers Rules” and admonished Vashisht-Rota to comply with Local 9 Civil Rule 83.9. (ECF 101.) Again in September, the magistrate judge noted Vashisht-Rota 10 “continue[d] to email the Court’s efile inbox, sometimes on an ex parte basis, seeking legal 11 advice or for other purposes not permitted under the Civil Local Rules or the Court’s 12 Chambers Rules.” (ECF 129.) The magistrate judge “once again admonished” Vashisht- 13 Rota “to cease contacting the Court for any purpose not expressly allowed under the Civil 14 Local Rules or the Court’s Chambers Rules.” (Id.) 15 Matters got worse. In October 2024, she sent this Court about 135 emails. The topics 16 again ran the gamut—including marriage proposals, whales in California, alleged 17 extramarital affairs, and property mold—but none of them were appropriate. An 18 excessively heavy barrage of such emails at the end of October and early November 19 resulted in this order to show cause: 20 In each of her related cases, plaintiff has been “limited to contacting this Court 21 no more than once per day, unless otherwise ordered,” due to the sheer number 22 of irrelevant or improper messages she sent to the Court’s email. (See ECF 100.) This limitation was specifically defined as “one contact with 23 chambers per day to discuss any and all cases,” as she has several cases 24 pending before this Court. (Id.) “Finally, any such contact or communication must strictly confine itself to requesting a hearing date for an authorized 25 motion.” (Id.) Despite that order -- and despite pointed reminders about it in 26 her related cases -- plaintiff has emailed this Court 75 times in the last 15 days, including over 20 times in a single day. As before, the topics have varied 27 wildly, ranging from her disagreement with court orders all the way to 28 discussing her uncle. Although the Court has shown plaintiff latitude given 1 her pro se status, her apparently flagrant violations of this Court’s order must end. 2

3 (ECF 140.) So, the Court ordered a “single, consolidated response of no more than 4 15 pages” for her to explain why she should not be sanctioned. (Id.) Yet Vashisht-Rota 5 elected to file multiple responses across her various cases. (See ECF 141 & 148; ECF 87 6 in 20-cv-0959-AGS-KSC; ECF 363 & 364 in 20-cv-0321-AGS-KSC.) 7 Even after the stark warning of that show-cause order, just a few days later, Vashisht- 8 Rota violated again by emailing the Court “five times” in a single day. (See ECF 365 in 9 20-cv-0321-AGS-KSC.) In response, the Court “admonished her to strictly adhere to the 10 Court’s orders going forward.” (Id.) Instead, between that last admonishment and two 11 weeks after being placed under a show-cause order for the same misbehavior, Vashisht- 12 Rota emailed this Court 30 additional times, including 10 in a single day. Not one was a 13 permissible request for a motion hearing date. 14 DISCUSSION 15 Under Rule 41, this Court may issue sanctions, up to and including “involuntary 16 dismissal,” for failure “to comply with” “a court order.” See Fed. R. Civ. P. 41(b). In 17 addition, this Court has the inherent authority to order the “outright dismissal of a lawsuit” 18 for court-order violations. See Chambers v. NASCO, Inc., 501 U.S. 32, 46 (1991). 19 A. Rule 41 Dismissal 20 In evaluating whether to dismiss a plaintiff’s case under Rule 41(b) for disobeying 21 a judicial order, the Court must weigh: “(1) the public’s interest in expeditious resolution 22 of litigation; (2) the court’s need to manage its docket; (3) the risk of prejudice to 23 defendants/respondents; (4) the availability of less drastic alternatives; and (5) the public 24 policy favoring disposition of cases on their merits.” Pagtalunan v. Galaza, 291 F.3d 639, 25 642 (9th Cir. 2002). 26 1. Public Interest in Expeditious Resolution 27 The first factor, concerning “expeditious resolution of litigation,” always weighs in 28 favor of dismissal.

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