Steven Mark Hayden v. Robert S. Vance, Jr., 708 F. App'x 976

Hayden, pro se, sued under 42 U.S.C. § 1983 and Alabama law alleging defendants conspired to assign an Alabama case (the Jefferson County Action) to an unconstitutional Commercial Litigation Docket, violating his due process rights.
The district court dismissed Hayden’s federal claims with prejudice and declined supplemental jurisdiction over state-law claims; Hayden appealed only the fee award.
The state Jefferson County court had entered an injunction and judgment against Hayden, found he persisted in harassing Cashion, and warned of severe sanctions; its judgment was affirmed by the Alabama Supreme Court. Hayden repeatedly sought to relitigate or collateral attack that judgment in state and federal forums and was held in contempt twice.
The magistrate judge found Hayden’s filings frivolous and recommended awarding fees under the court’s inherent powers; the district court adopted that recommendation and awarded $15,000 in attorneys’ fees and $76.06 in costs.
The district court relied on Hayden’s pattern of vexatious conduct (including frivolous motions and attempts to relitigate final state-court orders) in finding bad faith. Hayden appealed the fee award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether fees may be imposed under court’s inherent power for bad-faith litigation	Hayden denied bad faith and challenged the sanction	Defendants argued Hayden’s repeated, frivolous attacks and contempt findings justified fees	Court held inherent power authorizes fees for bad-faith, vexatious conduct and affirmed award
Whether the district court applied correct standard/review	Hayden contended errors in the fee determination	Defendants argued district court applied proper abuse-of-discretion standard	Court reviewed for abuse of discretion and found no clear error
Whether district court could consider filings from other cases / take judicial notice	Hayden objected to reliance on documents from other suits	Defendants pointed to those documents as record exhibits and judicially noticeable	Court held use of those documents proper and judicial notice permissible
Timeliness/ability to challenge dismissal or seek relief under Rule 60(b)	Hayden attempted to challenge dismissal and sought to void the judgment	Defendants argued appeal was untimely and Rule 60(b) relief unjustified	Court noted appeal of dismissal was untimely and Hayden failed to meet Rule 60(b) justification standard

Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (courts have inherent power to sanction for bad-faith, vexatious, or oppressive litigation conduct)
Barnes v. Dalton, 158 F.3d 1212 (11th Cir. 1998) (bad-faith conduct includes knowingly or recklessly raising frivolous arguments to harass)
Davis v. Nat’l Med. Enters., 253 F.3d 1314 (11th Cir. 2001) (attorneys’ fees award reviewed for abuse of discretion)
Gray ex rel. Alexander v. Bostic, 613 F.3d 1035 (11th Cir. 2010) (abuse-of-discretion standard and when it is shown)
United States v. Jones, 29 F.3d 1549 (11th Cir. 1994) (courts may take judicial notice of filings in other cases)
Zinni v. ER Solutions, 692 F.3d 1162 (11th Cir. 2012) (district court retains jurisdiction to consider attorneys’ fees and costs after judgment)
Cavaliere v. Allstate Ins. Co., 996 F.2d 1111 (11th Cir. 1993) (standard for relief under Rule 60(b))