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Mina v. United States District Court Ex Rel. Eastern District of Pennsylvania
710 F. App'x 515
| 3rd Cir. | 2017
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Background

  • Pro se litigant Anthony Mina filed multiple suits in the Eastern District of Pennsylvania challenging actions by a federal judge, Clerk’s Office employees, and the District Court for not providing transcripts and sealed summonses in prior cases.
  • The United States filed a statement of interest seeking dismissal and a filing injunction against Mina; the District Court dismissed the complaint based on immunity and later issued a filing injunction (then briefly vacated it) and struck Mina’s amended complaint.
  • Mina sought reconsideration claiming he did not receive the Government’s filing, filed an opposition to the Government’s statement, and submitted an amended complaint; the District Court reimposed a narrowly tailored filing injunction limited to suits against the United States and its employees and struck the amendment as futile.
  • Mina appealed the District Court’s dismissal, the filing injunction, and the order striking his amended complaint; the Third Circuit exercised summary affirmation.
  • The District Court concluded defendants were entitled to judicial or quasi-judicial immunity and prior orders foreclosed Mina’s requested relief, so dismissal with prejudice and striking the amendment was proper.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the complaint survives dismissal Mina argued defendants denied access to transcripts/sealed summonses, violating his civil rights Defendants asserted judicial/quasi-judicial immunity and that prior orders foreclosed relief Court affirmed dismissal: defendants entitled to immunity; claims futile
Whether dismissal should be without prejudice or with leave to amend Mina sought to amend and proceed Defendants argued amendment would be futile given immunity and prior rulings Court affirmed dismissal with prejudice and struck amended complaint as futile
Whether a filing injunction was proper Mina contested notice and scope; argued he did not receive Government’s filing Government and District Court argued Mina repeatedly filed meritless, repetitive suits; injunction needed and narrow Court affirmed injunction: Mina abused judicial process; he received notice and injunction was narrowly tailored

Key Cases Cited

  • Stump v. Sparkman, 435 U.S. 349 (establishes judicial immunity for judicial acts)
  • Gallas v. Supreme Court of Pa., 211 F.3d 760 (recognizes quasi-judicial immunity for court personnel)
  • Brow v. Farrelly, 994 F.2d 1027 (sets standards for pre-filing injunctions against vexatious litigants)
Read the full case

Case Details

Case Name: Mina v. United States District Court Ex Rel. Eastern District of Pennsylvania
Court Name: Court of Appeals for the Third Circuit
Date Published: Oct 16, 2017
Citation: 710 F. App'x 515
Docket Number: 17-1768
Court Abbreviation: 3rd Cir.