Dowling v. United States Attorney's Office, 4:24-cv-00373

Angela Dawn Dowling, proceeding pro se, filed 28 lawsuits in the District of Arizona and other venues, consistently alleging claims without supporting factual allegations.
The Court previously warned Dowling she could face a vexatious litigant injunction if she continued filing frivolous lawsuits after dismissing approximately 15 of her cases.
Despite the warning, Dowling filed three more cases, prompting the Court to review her entire litigation history in federal court (Arizona and Phoenix divisions).
The complaints typically lacked specific facts, failed to state a claim, and did not establish federal court jurisdiction, particularly failing to allege proper venue in Arizona.
The Court denied Dowling’s requests to proceed in forma pauperis and dismissed all pending actions with prejudice, also barring her from filing further lawsuits as a vexatious litigant going forward unless pre-filing requirements are met.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dowling’s complaints sufficiently state a legal claim	Dowling alleged various torts, fraud, and civil rights violations, but without specific facts	Defendants argue complaints are conclusory, lack facts, and lack jurisdiction	Complaints are factually and legally frivolous; dismissed
Whether proper federal jurisdiction and venue were established	Dowling alleged citizenship in several states without factual support, and claimed damages for out-of-state events	Defendants argued venue and jurisdiction not established, as events and parties lacked Arizona nexus	No subject-matter jurisdiction or venue in Arizona; dismissed
Whether plaintiff qualifies as a vexatious litigant	Dowling continued filing new, similar cases despite warnings	Defendants (or court) argue repetitive, baseless filings abuse the judicial process	Dowling declared a vexatious litigant; pre-filing injunction imposed
Eligibility to proceed in forma pauperis after repetitive frivolous filings	Dowling sought IFP status in numerous cases	Defendants/court argue continued frivolous filings preclude privilege of IFP	IFP status denied in all pending and future cases

Ashcroft v. Iqbal, 556 U.S. 662 (pleadings must state plausible claims with factual support)
Bell Atl. Corp. v. Twombly, 550 U.S. 554 (complaints require more than bare conclusions to survive dismissal)
De Long v. Hennessey, 912 F.2d 1144 (standards for imposing pre-filing orders on vexatious litigants)
Smart v. Heinze, 347 F.2d 114 (in forma pauperis proceeding is a privilege, not a right)
Tripati v. First Nat'l Bank & Trust, 821 F.2d 1368 (courts must deny IFP if the complaint is patently frivolous)