Whether a pre-filing injunction conditioning court access on monetary sanctions violates due process and the right to access courts under the All Writs Act

1. Whether an order imposing circuitand state-wide pre-filing injunctions conditioned on purging monetary sanctions exceeds the All Writs Act, violates due process, and conflicts with this Court’s and the Fifth Circuit’s precedents requiring injunctions to be narrowly tailored and to preserve access to courts. 2. Whether a stay is warranted under Nken v. Holder, 556 U.S. 418 (2009), because Applicant has a strong likelihood of success (or, at minimum, serious questions going to the merits), faces irreparable harm absent a stay, and the balance of equities and public interest favor interim relief. JURISDICTION This Application is made under Supreme Court Rules 22 and 23 to the Circuit Justice. The Fifth Circuit entered an order on October 31, 2025 denying a stay pending appeal in No. 25-60598. The district court’s Order issued October 22, 2025 in No. 2:24-cv-91-KS-MTP. This Court has authority to grant interim relief in aid of its potential jurisdiction. PROCEDURAL BACKGROUND e On October 22, 2025, the district court (S.D. Miss.) entered an Order granting contempt remedies and a broad pre-filing injunction that (i) prohibits Applicant from filing any new actions, or even moving for leave to file, in any federal court within the Fifth Circuit and in Mississippi and Texas state courts unless and until he first pays sanctions from this and prior proceedings and also obtains leave; and (ii) ties access to courts to purging monetary contempt. The Order also imposes ongoing per-diem obligations until property moves are completed under court-controlled procedures. e Applicant noticed appeal to the Fifth Circuit (No. 25-60598) and sought an emergency stay. On October 31, 2025, a panel denied a stay, with Judge Haynes stating she would grant a short temporary stay to consider the case. e The injunction’s immediate effect is to bar Applicant’s participation or filings in related forums (including defending himself when opposing parties take action), while exposing him to criminal-contempt risk for non-payment. e Applicant promptly filed in the Fifth Circuit: (1) an Emergency Motion for Administrative Stay pending reconsideration of the denial of stay; and (2) a Motion for Panel Rehearing of the denial of stay. Both remain pending as of this filing. STANDARD Stays pending appeal are governed by the familiar four factors: (1) a reasonable probability of success on the merits; (2) irreparable harm; (3) the balance of equities; and (4) the public interest. Nken v, Holder, 556 U.S. at 426; Merrill v. Milligan, 595 U.S. ___ (2022) (Kavanaugh, J., in chambers). Administrative stays may issue to preserve the status quo while the Court or a Justice considers the request. See Sup. Ct. R. 22, 23. ARGUMENT I. Applicant Is Likely to Succeed on the Merits (or Presents Serious Merits Questions) A. The injunction is overbroad and not narrowly tailored. The district court’s order extends far beyond the case before it: it conditions all future filings across multiple sovereign court systems (federal Fifth Circuit courts and two states’ courts) on pre-payment of monetary sanctions and a special leave procedure. Injunctions restricting access to courts must be narrowly tailored, targeted to specific vexatious conduct, and preserve legitimate filings. The Order here functions as a near-categorical bar, not calibrated to particular claims or forums, and imposes a pay-to-access prerequisite even for defensive or non-frivolous filings. B. The order conflicts with access-to-courts and due-process principles. This Court has repeatedly recognized that litigants retain a qualified right of access; courts may deter abusive conduct, but cannot extinguish access through financial conditions that thwart good-faith filings, especially where liberty-threatening contempt exposure is leveraged to force payment. The All Writs Act is not a roving commission to restructure access to other courts or to bind state courts absent strict necessity and narrow tailoring. C. The Or