Smith v. Wrigley, 1:25-cv-00069

Eric Smith, a Utah resident, filed a pro se federal lawsuit challenging North Dakota Senate Bill 2382 (“SB 2382”), which establishes restrictions on those deemed "vexatious litigants."
SB 2382 codifies North Dakota Supreme Court Administrative Rule 58, allowing courts to limit the litigation activities of individuals declared vexatious.
Smith alleges the new statute is vague, overly restrictive, and unconstitutional under both the U.S. and North Dakota Constitutions, citing potential bias and infringement of rights.
Smith was previously subject to restrictions under the North Dakota Supreme Court vexatious litigant roster but did not allege any new denial of filing rights under the new statute.
The lawsuit was filed before SB 2382 went into effect; by the time of the court’s review, the law had already been enacted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing	Smith claims unconstitutional injury from SB 2382 and seeks injunction	No direct response, defendant not yet served	Smith lacks standing; no concrete injury alleged or suffered
Ripeness	Argues the law is presently injurious and should be enjoined	Not reached	No actual or imminent injury; claim not ripe
Mootness (legislative process)	Sought to enjoin legislative process before enactment	Not contested	Moot; SB 2382 already enacted
Constitutionality	Argues statute is vague, restrictive, promotes judicial bias, violates multiple constitutional rights	Not reached	Court does not reach merits due to lack of jurisdiction

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard for plausibility)
Braden v. Wal-Mart Stores, Inc., 588 F.3d 585 (pleadings review standard)
Bender v. Williamsport Area Sch. Dist., 475 U.S. 534 (limits on federal court jurisdiction)
Ashcroft v. Iqbal, 556 U.S. 662 (distinction between factual allegations and legal conclusions)
Stone v. Harry, 364 F.3d 912 (standard for pro se pleadings)