Ringgold-Lockhart v. County of Los Angeles, No. 11-57231 (9th Cir. 2014)
Annotate this CasePlaintiffs Ringgold and Ringgold-Lockhart appealed the district court's vexatious litigant order. The court concluded that the district court provided proper notice and an opportunity to be heard, in accordance with the court's case law's first procedural requirement and due process; the district court compiled an adequate record to permit the court to review the basis of its order; the district court failed to consider alternative sanctions before issuing this injunction; the district court erred by issuing an order against Ringgold-Lockhart on the basis of state litigation in which he played no part; and the scope of the order is too broad in several respects. Accordingly, the court vacated the order and remanded for further proceedings.
Court Description: Civil Rights. The panel vacated the district court’s order declaring plaintiffs, attorney Nina Ringgold and her son Justin Ringgold-Lockart, vexatious litigants and imposing a pre- filing order, and remanded for further proceedings. The panel held that in light of the constitutional concerns such pre-filing orders implicate, the district court erred by relying in large part on Nina Ringgold’s motions practice over the course of just two federal lawsuits, without considering less restrictive sanctions. The district court also erred by holding Nina Ringgold’s state litigation against Justin Ringgold-Lockhart, without a record indicating that he participated in that litigation. Finally, the panel held that there was an insufficiently close fit between the terms of the injunction and the problem it purported to address.
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