Whether federal courts may impose sanctions under their inherent authority without a finding of bad faith when dismissing a pro se prisoner's civil rights lawsuit for technical noncompliance with local rules

No question identified. : 2. Absent an extension, a petition for a writ of certiorari would be due on December 7, 2025. This application is being filed more than 10 days in advance of that date, and no prior application has been made in this case. 3. This case presents a question that has sharply divided the circuits since this Court’s decision in Chambers v. NASCO, Inc., 501 U.S. 32 (1991): whether federal courts have the power to issue sanctions under their inherent authority without first finding “bad faith.” 4, James E. McNair, a Florida prisoner, filed a lawsuit under 42 U.S.C. § 1983 alleging that respondent violated the Eighth Amendment by withholding critical medication. As required by the U.S. District Court for the Northern District of Florida’s Local Rule 5.7(A), Mr. McNair used the court’s standard civil-rights complaint form for pro se prisoners. The form requires prisoners to list “all prior state and federal cases,” including “civil cases, habeas cases, and appeals,” to assist the court in performing PLRA screening under 28 U.S.C. $§ 1915(e)(2) and 1915A. 5. The district court dismissed the case without prejudice under 28 U.S.C. § 1915(e)(2)(B)G), which mandates that a court “shall dismiss the case at any time if [it] determines that ... the action ... is ... malicious.” In the court’s view, this action was “malicious” because Mr. McNair inadvertently omitted one habeas petition and an appeal of a later habeas petition from the complaint form. The court made clear that it viewed this dismissal as mandatory under the statute. It characterized the magistrate judge’s recommendation as urging dismissal “as malicious under 28 U.S.C. § 1915(e)(2)(B)() .” And the court agreed, stating: “Plaintiffs complaint is DISMISSED without prejudice as malicious under 28 U.S.C. § 1915(e)(2)(B)(i).” The court thus directed the Clerk to “note on the docket that this cause was dismissed pursuant to 28 U.S.C. § 1915(e)(2)(B)(@ and counts as a strike.” The district court did not mention its inherent authority or any form of discretion. 6. Mr. McNair appealed, arguing that his omissions on the form did not meet the PLRA’s “malicious” standard because they were inadvertent and immaterial. Rather than address that argument, the panel affirmed on an entirely different “alternative ground”: that the district court could have dismissed the case in its discretion under its “inherent authority” to enforce compliance with local rules. Slip op. at 2, 9. The panel repeatedly acknowledged that such dismissals are discretionary—not mandatory. Slip op. at 9-10, 13 (referring to the district court’s “considerable discretion” and noting that “[wle review [such dismissals] for an abuse of discretion” (citation omitted)). 7. The panel explained that the district court’s Local Rule 5.7(A) requires pro se prisoners to use the form and authorizes dismissal for noncompliance. Slip op. at 11-13. It held that “dismissal without prejudice was an appropriate exercise of the district court’s inherent authority to manage its docket and enforce the local rules,” and that the court “did not abuse its considerable discretion when it dismissed McNair’s suit for failure to comply with the complaint form’s explicit instructions.” Slip op. at 18. “That is so even if we would have gone the other way had the choice been ours to make.” Slip op. at 13-14 (cleaned up). The panel concluded: “The record supports the district court’s dismissal without prejudice of McNair’s § 1983 suit under its inherent authority to manage its docket and enforce applicable local rules. Accordingly, we affirm the district court’s judgment.” Slip op. at 14. 8. The Eleventh Circuit declined to make any finding as to whether Mr. MeNair’s omissions were intentional or event negligent, finding it unnecessary to do so. The Eleventh Circuit expressly held that although inherent authority sanctions typically require a finding of “bad faith,” a bad faith is not required where the sanction is a dismissa