Matthew X. Winters v. Corporal Jarvela, et al.; Matthew X. Winters v. J. O’Hanlon; Matthew X. Winters v. Corporal Willstead and Corporal Dobbs; Matthew X. Winters v. Vita Core Medical Staff and Nicole Do; Matthew X. Winters v. CPL. MacDonald, et al.

Summary

The Eastern District of Wisconsin imposes a filing restriction on inmate Matthew X. Winters after determining that he had filed or attempted to file more than twenty civil rights claims across multiple cases within a short period. The order limits Winters to two open cases before the court at a time, excludes habeas corpus petitions concerning his criminal convictions, and requires him to identify which two of five pending cases he wishes to pursue. The remaining cases are to be administratively closed subject to possible reopening, and Winters may seek modification or rescission of the restriction after three years.

Holdings

1. A federal district court may use its inherent authority and the All Writs Act to impose a prefiling restriction against a vexatious litigant whose conduct abuses the judicial process.
2. A filing restriction must be narrowly tailored to the type of abuse and may not absolutely bar access to the courthouse; on these facts, limiting Winters to two open cases before the court, while exempting qualifying habeas petitions, was appropriate.

Questions Presented

1. Whether the district court may impose a prefiling restriction on a litigant who has filed an excessive number of repetitive or abusive complaints.
2. Whether the appropriate restriction must be narrowly tailored and preserve meaningful access to the federal courts.
3. Whether Winters should be limited to proceeding with no more than two open cases before the court, subject to an exception for habeas petitions relating to his criminal convictions.

Disposition

other