VANDERHALL v. PENSACOLA NARCOTICS UNIT, 3:13-cv-00357

Plaintiff Tyrone Paul Vanderhall, an Escambia County Jail inmate, filed a 42 U.S.C. § 1983 civil-rights complaint alleging Defendants (Pensacola Narcotics Unit and eight officers) obtained and executed an illegal search warrant based on an unreliable confidential informant; he sought damages and injunctive relief.
Plaintiff proceeded in forma pauperis, so the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B).
The complaint form required disclosure of prior civil actions; Plaintiff marked he had initiated other federal actions and listed one habeas case challenging the search warrant, but omitted a separately filed federal civil-rights action (No. 3:13cv308) that he had filed shortly before.
The court took judicial notice of the omitted case and concluded the omission was a deliberate false response intended to hide litigation history.
The magistrate judge found the false statement constituted abuse of the judicial process, that pro se status did not excuse the omission, and recommended dismissal without prejudice as a sanction and a warning about future false statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint should be dismissed for an untruthful omission of prior federal litigation on the form	Vanderhall omitted a prior federal civil action (no express defense asserted in opinion)	Court treated omission as deliberate concealment of litigation history	Dismissal without prejudice recommended for abuse of process under §1915(e)(2)(B)(i)
Whether the court should decide the merits of the §1983 claims (illegal search; Fourth, Sixth, Fourteenth Amendment)	Alleged illegal warrant and constitutional violations	Not addressed on merits due to procedural disposition	Merits not reached; claims not decided
Whether pro se status excuses inaccurate or false statements on court forms	Vanderhall was pro se and incarcerated	Court: pro se status does not excuse false responses and does not permit undermining the form's purpose	Pro se status is not an excuse; accuracy required
Whether dismissal without prejudice is an appropriate sanction for the omission	(No mitigation accepted in opinion)	Court: dismissal deters abuse and preserves form integrity; warning that harsher sanctions may follow	Dismissal without prejudice deemed appropriate; plaintiff may refile if desired

Warren v. Guelker, 29 F.3d 1386 (9th Cir. 1994) (misrepresentations by pro se, in forma pauperis prisoner may violate Rule 11)
United States v. Roberts, 858 F.2d 698 (11th Cir. 1988) (failure to object may limit scope of appellate review)