Larry Klayman v. Neomi Rao, 49 F.4th 550

Klayman was plaintiff in long-running litigation against Judicial Watch (Judicial Watch I) presided over by Judge Colleen Kollar-Kotelly; jury returned a $2.3M verdict against him, which the D.C. Circuit affirmed and the Supreme Court denied certiorari.
Klayman filed a separate Rule 60 action (Judicial Watch II) before Judge Tanya S. Chutkan seeking vacatur; that complaint was dismissed and the D.C. Circuit affirmed.
After denial of rehearing en banc, Klayman filed a pro se suit naming Judges Kollar-Kotelly, Chutkan, and all members of the D.C. Circuit, alleging First, Fifth, and Fourteenth Amendment violations based on prior rulings.
The district court dismissed Klayman’s new complaint sua sponte.
Klayman appealed; the D.C. Circuit affirmed, holding the district court lacked jurisdiction to review other federal courts’ decisions, the claims were barred by res judicata/collateral estoppel, and equitable relief was unwarranted because adequate legal remedies existed.
The court also rejected Klayman’s request to transfer venue based on an argument that all judges in the district should be recused.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to review prior courts’ decisions	Klayman argued the district court could entertain an independent Rule 60(d)(1) action to vacate prior judgments	Other courts and defendants argued a district court cannot review or void decisions of other federal courts	Court held district courts lack jurisdiction to review/void decisions of other federal courts; dismissal appropriate
Preclusion (res judicata / collateral estoppel)	Klayman sought to relitigate errors from Judicial Watch I/II as constitutional violations	Defendants argued issues were already litigated and decided in prior cases	Court held claims barred by issue preclusion/res judicata
Availability of equitable relief (injunction/vacatur)	Klayman sought vacatur and a new trial as equitable relief	Defendants argued Klayman had adequate remedies at law (appeal, certiorari) so equitable relief inappropriate	Court held Klayman had adequate legal remedies and thus was not entitled to injunctive/declaratory relief
Venue/recusal / transfer	Klayman argued all judges in D.D.C. should be recused and the case transferred because impartiality might reasonably be questioned	Defendants argued challenging prior judges’ rulings alone does not require recusal or justify transfer; no authority for transfer on that basis	Court held recusal not warranted merely because prior rulings are challenged and no basis to transfer venue

Celotex Corp. v. Edwards, 514 U.S. 300 (1995) (orders of a court of first instance respected until reversed by orderly review; limits on collateral attacks)
Walker v. Birmingham, 388 U.S. 307 (1967) (orders of courts must be respected pending appeal)
Smalls v. United States, 471 F.3d 186 (D.C. Cir. 2006) (district courts lack authority to review decisions of other federal courts)
Mullis v. U.S. Bankr. Ct. for the Dist. of Nev., 828 F.2d 1385 (9th Cir. 1987) (prohibiting horizontal appeals between district courts)
Allen v. McCurry, 449 U.S. 90 (1980) (principles of collateral estoppel precluding relitigation of decided issues)
Yamaha Corp. of Am. v. United States, 961 F.2d 245 (D.C. Cir. 1992) (once an issue is decided, the entire issue is precluded)
Younger v. Harris, 401 U.S. 37 (1971) (equity courts should not act when adequate legal remedies exist)
Richards v. Delta Air Lines, Inc., 453 F.3d 525 (D.C. Cir. 2006) (general rule that injunctive relief will not issue when adequate legal remedy exists)
Wilson v. Schnettler, 365 U.S. 381 (1961) (availability of appeal provides an adequate legal remedy)
Banks v. Office of Senate Sergeant-At-Arms & Doorkeeper of U.S. Senate, 471 F.3d 1341 (D.C. Cir. 2006) (denial of mandamus where adequate remedy at law exists)