Anthony Mina v. Chester County, 684 F. App'x 256

Pro se plaintiff Anthony Mina repeatedly filed sprawling complaints alleging a decades-long conspiracy involving dozens of defendants; prior substantially identical suit (No. 14-cv-6261) was dismissed for lack of federal jurisdiction and affirmed on appeal.
Mina filed a new complaint in 2015 containing the same 1,206 allegations plus 52 more; the District Court dismissed it on March 10, 2016 for lack of subject-matter jurisdiction and denied pending motions.
Mina filed a Rule 59(e) motion (tolling appeal time), then multiple additional post-judgment motions: recusal, Rule 60(b), a second Rule 59(e)/reconsideration, and a motion for electronic filing access; the District Court denied these motions and Mina appealed.
The Court of Appeals held it lacked jurisdiction over challenges to the dismissal and the first Rule 59(e) denial because Mina’s notice of appeal was untimely as to those orders.
The Third Circuit nevertheless reviewed and affirmed denial of the recusal motion, the Rule 60(b)/second Rule 59(e) motions (as meritless and duplicative), and the denial of electronic-filing access.
The opinion warns that further duplicative or abusive filings may prompt sanctions and filing restrictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction over appeal of dismissal and first Rule 59(e) denial	Mina contends the District Court erred in dismissing the complaint and denying reconsideration	Appeal was filed too late; only the initial Rule 59(e) tolled the appeal period and subsequent motions did not	No jurisdiction to review those orders; appeal dismissed as to them
Recusal of District Judge	Mina argued recusal was required because the judge’s civil deputy was named in a later suit	Naming a judge’s staff member in another case is not grounds for the judge’s recusal	Denied — recusal motion was meritless
Rule 60(b) and second Rule 59(e) motions	Mina sought relief/reconsideration repeating prior arguments	Motions were duplicative of arguments already rejected; no new grounds for relief	Denied — motions lacked merit and raised previously litigated arguments
Access to electronic filing (ECF)	Mina sought permission to file electronically post-judgment	Case was closed; prior courts had previously granted and revoked such privileges for Mina due to abusive filings	Denied — no basis to grant ECF access; clerk may revoke privileges for abuse

Wiest v. Lynch, 710 F.3d 121 (3d Cir. 2013) (tolling effect of motions construed as Rule 59(e))
Turner v. Evers, 726 F.2d 112 (3d Cir. 1984) (subsequent post-judgment motions do not toll appeal period)
Bowles v. Russell, 551 U.S. 205 (U.S. 2007) (strict appeal-timeliness rule)
Long v. Atl. City Police Dep’t, 670 F.3d 436 (3d Cir. 2012) (appellate jurisdiction over collateral post-judgment orders)
Azubuko v. Royal, 443 F.3d 302 (3d Cir. 2006) (naming judge in another suit does not automatically require recusal)
Mathis v. Huff & Puff Trucking, Inc., 787 F.3d 1297 (10th Cir. 2015) (conflict of interest for clerk vs. judge disqualification)
Exxon Shipping Co. v. Baker, 554 U.S. 471 (U.S. 2008) (reiteration that reconsideration requires new arguments or law)
Lazaridis v. Wehmer, 591 F.3d 666 (3d Cir. 2010) (standard for denial of reconsideration)