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