Anne Block v. Washington State Bar Assoc., 18-35690

Anne Block repeatedly sued state and local entities (including the WSBA) alleging misconduct; multiple prior suits were dismissed and two dismissals were affirmed on appeal.
The Western District of Washington sua sponte entered a vexatious-litigant pre-filing bar (Initial Bar Order); the Ninth Circuit vacated that order for lack of notice and remanded.
On remand the district court reimposed an identical pre-filing bar (Reimposed Bar Order); Block appealed that reimposition (20-35025) and separately challenged the Pennsylvania-to-Washington transfer and related matters (18-35690).
The Ninth Circuit reviewed the Reimposed Bar Order under the De Long/Ringgold-Lockhart framework (notice/opportunity, adequate record, substantive findings, narrow tailoring).
The court found notice/opportunity present on remand; held the district court had an adequate record (including prior dismissals and emails not barred by FRE 408); found substantive findings of frivolousness/harassment; and found the order narrowly tailored.
The Ninth Circuit affirmed the Reimposed Bar Order, denied Block’s request to remand the transferred case, rejected recusal/disqualification arguments against Judge Martinez, and affirmed dismissal under the validated bar.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of reimposed vexatious-litigant pre-filing order (procedural requirements)	Reimposition improper because initial order vacated for lack of notice; alleged deficiencies persist	On remand Block had notice/opportunity; district court complied with De Long requirements	Affirmed: notice/opportunity satisfied and court followed De Long framework
Adequacy of the record (including use of emails)	Emails attached to declaration are inadmissible under FRE 408 and record is insufficient	Emails were offered to show harassment (not settlement) and prior dismissed cases listed support need for injunction	Affirmed: record adequate; emails admissible for harassment evidence
Substantive findings of frivolousness/harassment	District court failed to make sufficient substantive findings to justify a pre-filing injunction	Court relied on numerous dismissed suits, prior sanctions/fee awards, and continuing harassing emails	Affirmed: substantive findings supported by number and content of filings
Narrow tailoring and consideration of alternatives	Order not narrowly tailored; judge failed to consider less-restrictive alternatives (relies on Safir)	Order only imposes prescreening, allows meritorious claims; Safir factors not adopted in Ninth Circuit	Affirmed: order narrowly tailored; Safir not required and would not change result

Ringgold-Lockhart v. County of L.A., 761 F.3d 1057 (9th Cir. 2014) (sets procedural and substantive requirements for vexatious-litigant orders)
De Long v. Hennessey, 912 F.2d 1144 (9th Cir. 1990) (framework requiring notice, record, findings, and narrow tailoring)
Molski v. Evergreen Dynasty Corp., 500 F.3d 1047 (9th Cir. 2007) (limits on pre-filing injunctions and ability to file meritorious claims)
Safir v. U.S. Lines, Inc., 792 F.2d 19 (2d Cir. 1986) (alternative-factors framework—useful but not adopted by Ninth Circuit)
Posnanski v. Gibney, 421 F.3d 977 (9th Cir. 2005) (limits on appellate review of district-court transfer orders)
DeNardo v. Municipality of Anchorage, 974 F.2d 1200 (9th Cir. 1992) (membership in bar association does not by itself require judge recusal)
Riss v. Angel, 934 P.2d 669 (Wash. 1997) (state-law discussion on liability of members of nonprofit associations)