Pavilonis v. King
United States Court of Appeals for the First Circuit
626 F.2d 1075 (1980)
Pavilonis (plaintiff) filed two nearly identical civil rights complaints against Boston school officials (defendants), providing almost no factual detail beyond bare citations to the Fourteenth Amendment and § 1986; a magistrate discovered five other similarly deficient complaints Pavilonis had filed against some of the same defendants, and recommended restricting her from filing new actions without court permission, which the district judge adopted along with dismissing the current complaints. Pavilonis appealed, arguing the filing injunction was unconstitutional.
Whether a litigant may be enjoined from initiating litigation without court permission where the litigant has a history of filing frivolous and repetitive complaints suffering from the same deficiencies.