Eric L. Wakefield v. Franklin County Sheriff Department, David Bartoni, and Kyle Bacon; Eric L. Wakefield v. Franklin County Jail, Anthony Skobel, S. Barra, Kieth Lampley, Matt Pemberton, Ann Lytle, Frankie Valesquez, John Wheatley, Megan Duiguin, Mallory Kelley, Kenny Jacobs, Gage Darnell, Patricia Jackson, Gerald Dorris, Casey Jackson, Jacob Bartoni, and Zane Young

Summary

The court denied Wakefield’s first motion for sanctions against former and opposing counsel, concluding that the alleged conduct did not establish constitutional or professional violations. The court struck his second pro se sanctions motion because he was represented by counsel and directed the Clerk to refuse future pro se filings from him while represented.

Holdings

1. The first motion for sanctions was denied because plaintiff alleged no facts establishing a constitutional violation by private counsel, a violation of professional-conduct rules, or a breach of the attorney-client privilege.
2. A litigant represented by counsel may not file pro se submissions in the same proceeding, and the court may strike such a submission as improper.

Questions Presented

1. Whether plaintiff's first motion for sanctions stated a basis for sanctions against his former attorneys or opposing counsel.
2. Whether a represented party may file a pro se motion and, if not, whether the court may strike that motion and reject future pro se filings.

Disposition

other