Brown v. Illinois Department of Correctional, 3:13-cv-00793

Plaintiff Perry Brown initiated this action in August 2013 by filing a motion for a preliminary injunction and TRO; the Court denied that motion and instructed Brown to file a complaint, which he never did.
The district court entered judgment dismissing the case on September 13, 2013; the case has remained closed since then.
Brown filed multiple post-judgment filings and three notices of appeal; the Court of Appeals dismissed at least two appeals for failure to pay filing fees and one for being untimely.
On September 6, 2017 Brown filed a “Petition for Review” (Doc. 39) which did not request any relief and contained a mixture of prior filings and unintelligible material.
Brown also filed a Motion to Appoint Counsel (Doc. 42) consisting largely of prior filings and no new facts showing he tried to recruit counsel, and a separate incoherent Motion (Doc. 52) alleging, in the gist, medical/medication complaints but offering no viable relief in this closed case.
The court treated the filings as improper or deficient, struck Doc. 39, denied Doc. 42 and Doc. 52, and warned Brown against further frivolous filings in the closed case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doc. 39 ("Petition for Review") is a proper motion	Brown submitted Doc. 39 purporting to seek review/recall of mandate and IFP relief	Court noted Doc. 39 requests no relief and mixes unrelated materials	Doc. 39 stricken for failing to request relief under Fed. R. Civ. P. 7(b)
Whether counsel should be appointed (Doc. 42)	Brown sought appointment of counsel to assist with claims and appeals	Court observed Brown did not show he tried to obtain counsel and case is closed	Motion denied: Brown failed Pruitt threshold (no attempt to recruit counsel) and case is closed so appointment would be futile
Whether Doc. 52 states a claim or provides relief in this case	Brown alludes to medication/medical treatment and mental health issues	Court found the allegations were not previously pleaded in this action and the case is closed; filings are incoherent and lack plausible facts	Motion denied; new allegations cannot be raised in this closed case; Brown advised to file a new case if he wishes to pursue medication claims
Whether court should sanction continued filings in the closed case	Brown continued filing appeals and motions after final judgment and appellate dismissals	Court notes repeated, untimely, and frivolous filings waste resources	Court warned of possible sanctions (fines, contempt, filing restrictions) if vexatious filings persist

Pruitt v. Mote, 503 F.3d 647 (7th Cir.) (two-part test for recruiting counsel for indigent plaintiffs)
Farmer v. Haas, 990 F.2d 319 (7th Cir.) (standard referenced for appointing counsel inquiry)
U.S. ex rel. Verdone v. Circuit Court for Taylor Cty., 73 F.3d 669 (7th Cir.) (court’s authority to impose sanctions for frivolous filings)
Alexander v. United States, 121 F.3d 312 (7th Cir.) (recognition of courts’ inherent powers to curb vexatious litigation)
Support Systems Int’l Inc. v. Mack, 45 F.3d 185 (7th Cir.) (authority on protecting courts from abusive litigation)