Lundahl v. Eli Lilly and Company, 2:13-cv-00241

Federal court in the District of Wyoming considers pre-filing restrictions on Holli Lundahl due to abusive litigation history.
Court grants Eli Lilly and Cheryl Schrock's motion to impose restrictions and requires authorization to file pro se actions.
Court relies on the inherent power to regulate filings of abusive litigants under 28 U.S.C. § 1651(a).
Court catalogs Lundahl’s extensive history of vexatious filings across multiple courts, including prior sanctions and restrictions.
Court imposes lasting filing restrictions: Lundahl barred from filing civil matters in Wyoming unless represented by counsel or granted permission after a specific petition and notarized affidavit requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to impose restrictions	Lundahl argues Court lacks authority	Court has inherent authority to curb abuse	Yes; court has authority to impose restrictions
Lundahl’s litigation history	Not abusive or harassing	History is lengthy and abusive	History deemed lengthy and abusive
Notice and opportunity to be heard	Not adequately heard	Plaintiff had opportunity to respond	Plaintiff was provided notice and opportunity to oppose before order issued
Scope of restrictions	Restrictions are too broad	Restrictions tailored to prevent harassment	Restrictions properly tailored; include pro se filing conditions and alias prohibitions
Procedure to seek permission to file pro se	Process unclear/unfair	Clear process with petition and notarized affidavit required	Procedural steps clarified and imposed

Tripati v. Beaman, 878 F.2d 351 (10th Cir. 1989) (inherent power to enjoin abusive litigants under 28 U.S.C. § 1651(a))
Lundahl v. Nar Inc., 434 F.Supp.2d 855 (D.Idaho 2006) (sanctions for abusive litigation; district court findings of harassment)
Lundahl v. Eli Lilly & Co., 296 F.3d 936 (10th Cir. 2002) (filing restrictions against an abusive litigator)