Brown v. Mullis, 3:24-cv-00706

William Arthur Brown was convicted on several federal charges in 1993, including engaging in a continuing criminal enterprise, conspiracy, and money laundering.
Brown previously argued, unsuccessfully, that his trial attorney’s conflict of interest resulted in an unfair trial, an issue waived after a recusal hearing.
In 2000, Brown sued participants in his prosecution (attorneys, prosecutors, FBI agent) for conflict of interest and conspiracy, but the suit was dismissed as frivolous and a pre-filing injunction was imposed against him.
Brown separately obtained partial post-conviction relief regarding sentencing, but his main convictions and judgment were repeatedly affirmed.
In 2024, Brown filed the present pro se complaint alleging a new criminal conspiracy to keep him incarcerated, essentially repeating the 2000 claims without prior court approval despite the injunction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Bar on relitigating dismissed claims	That prior claims should be redressed due to alleged newly uncovered criminal act	Claims already dismissed with prejudice	Plaintiff barred from raising identical claims again
Statute of Limitations	Claims remain timely due to recent discoveries	Claims are decades old and untimely	Claims are time-barred by statute of limitations
Frivolity/Prefiling Injunction	Complaint raises non-frivolous, meritorious points	Complaint is frivolous, repeat of old case	Complaint dismissed as frivolous, injunction violated
Immunity/Failure to state claim	Defendants acted outside their official roles	Defendants entitled to immunity	Claims fail to state a claim; defendants immune

Neitzke v. Williams, 490 U.S. 319 (standards for frivolity dismissals under § 1915)
Haines v. Kerner, 404 U.S. 519 (liberal construction for pro se filings)
Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (liberal construction does not save meritless claims)
United States v. Brown, 202 F.3d 691 (prior appeal involving Brown’s conflict of interest claim)