Stora v. New York City Board of Elections and Rusat Ramgopal

Summary

The Eastern District of New York granted the New York City Board of Elections’ motion for an anti-filing injunction against pro se plaintiff Skiboky Stora. The court found that Stora had a substantial history of vexatious and unsuccessful litigation, had caused needless expense and burdens, and was unlikely to be deterred by lesser sanctions. The injunction bars Stora from filing further federal actions against the Board or its personnel in the Eastern or Southern Districts of New York without leave of the applicable Chief Judge.

Holdings

1. An anti-filing injunction was warranted because Plaintiff's substantial history of vexatious and baseless litigation, lack of an objective good-faith expectation of prevailing, needless expense and burden imposed on the Board and courts, and the inadequacy of lesser sanctions outweighed the countervailing consideration of his pro se status.
2. A district court may not impose an anti-filing injunction sua sponte without notice and an opportunity to be heard, and those requirements were satisfied because the Board requested the injunction in advance, briefed it, and the court gave Plaintiff additional time to respond.
3. The anti-filing injunction was appropriately limited because it barred only new federal actions against the New York City Board of Elections or its personnel in the Eastern or Southern Districts of New York and permitted potentially meritorious filings with leave of the applicable chief judge.

Questions Presented

1. Whether the district court should impose an anti-filing injunction based on Plaintiff's history of vexatious and repetitive litigation.
2. Whether Plaintiff received adequate notice and an opportunity to be heard before the anti-filing injunction was imposed.
3. Whether the proposed injunction was sufficiently narrow and tailored to avoid being overbroad.

Disposition

other