LIN v. HUDSON CITY SAVINGS BANK, 3:18-cv-15387

Background

The dispute originates from a state foreclosure action (M&T Bank successor to Hudson City v. Lin), where the state court granted summary judgment for the banks in December 2016 and entered final judgment July 28, 2017.
Plaintiffs Jay and Irene Lin repeatedly filed motions in state court (motion to vacate, multiple stays, an appeal) that were denied as untimely, procedurally deficient, or meritless; the Appellate Division affirmed those denials.
Plaintiffs filed multiple federal suits and pleadings attacking the state-court foreclosure rulings, including a 2018 federal complaint alleging FDCPA and bankruptcy automatic-stay violations; those filings were dismissed, voluntarily withdrawn, or denied on procedural/merits grounds.
Defendants moved to deem Plaintiffs vexatious and to enjoin future filings under the All Writs Act and to recover fees under Rule 11; Plaintiffs cross-moved for relief and sanctions against Defendants.
The Court found a pattern of repetitive, frivolous filings (noting Mr. Lin is an attorney with prior sanctions), concluded Plaintiffs are vexatious litigants, and awarded Defendants attorneys’ fees in principle (directing Defendants to file a fee petition).
The Court reserved ruling on a pre-filing injunction under the All Writs Act, ordered Plaintiffs to show cause within 20 days why they should not be enjoined from filing further actions related to the foreclosure without prior court approval, and denied Plaintiffs’ prior sanctions requests (which the Third Circuit had affirmed).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiffs are vexatious litigants	Plaintiffs maintain their challenges to foreclosure are legitimate	Plaintiffs repeatedly file meritless, duplicative, harassing claims despite adverse rulings	Court: Plaintiffs are vexatious litigants
Whether to enjoin future filings under All Writs Act	Injunction unnecessary and overly restrictive	Injunction needed to prevent harassment and docket abuse	Court: Reserved; ordered 20-day show-cause why injunction should not issue
Whether monetary sanctions (fees) under Rule 11 or otherwise are warranted against Plaintiffs	Plaintiffs dispute that filings were baseless and oppose sanctions	Defendants seek attorneys’ fees for defending against repeated frivolous filings	Court: Awards fees in principle; directs Defendants to submit fee petition for amount determination
Plaintiffs’ request to sanction Defendants and counsel	Plaintiffs claim Defendants acted improperly and seek sanctions	Defendants deny improper conduct; movants contend no basis for sanctions	Court: Plaintiffs’ prior sanctions requests were denied; Third Circuit affirmed; no new sanctions against Defendants granted here

Key Cases Cited

Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (recognizing courts’ inherent power to sanction and protect their processes)
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990) (explaining Rule 11’s central deterrent purpose against baseless filings)
Abdul‑Akbar v. Watson, 901 F.2d 329 (3d Cir. 1990) (All Writs Act may support pre‑filing injunctions but such orders must be narrowly tailored)
In re Packer Ave. Assocs., 884 F.2d 745 (3d Cir. 1989) (upholding injunctions restricting repetitive meritless filings)
Doering v. Union Cty. Bd. of Chosen Freeholders, 857 F.2d 191 (3d Cir. 1988) (discussing methods and forms of sanctions including fees)
Lieb v. Topstone Indus. Inc., 788 F.2d 151 (3d Cir. 1986) (articulating Rule 11’s duty to ‘‘look before leaping’’)
In re Oliver, 682 F.2d 443 (3d Cir. 1982) (emphasizing access to courts and careful use of pre‑filing restrictions)
In re Prudential Ins. Co. Am. Sales Practice Litig., 278 F.3d 175 (3d Cir. 2002) (inherent sanction power reserved for egregious conduct when other remedies inadequate)
DiPaolo v. Moran, 407 F.3d 140 (3d Cir. 2005) (district courts have broad discretion in selecting sanction types)