Don't Forget Your First-Year Civil Procedure Lessons on Personal Jurisdiction

From Castro v. Doe, decided Monday by Judge Mark Pittman (N.D. Tex.):

John Anthony Castro filed this lawsuit on June 16, 2023, alleging that former President Donald Trump, among others, conspired to publish defamatory, verifiably false statements about him on his Wikipedia page. These supposedly false statements include the notion that Castro is a "sleazy tax attorney," did not serve in the military, and is under federal indictment. Castro believes Trump is targeting him as retaliation for the over thirty federal lawsuits Castro has lodged against Trump concerning Trump's actions on January 6, 2021.

The court upheld the Magistrate Judge's conclusion that Castro is a vexatious litigant:

Castro's June 2023 original complaint represented the tenth case he has filed in this District in the last five years, six of which have been filed since April 2021. And that says nothing of his dozens of other cases filed across the country in the last few years….

In his Objections, Castro explains, case by case, how each is meritorious and does not support a finding that he is clogging the judicial machinery with meritless litigation. Of note, roughly half of the cases … have suffered problems related to the same issue: jurisdiction, even to Castro's own admission. Even as recently as March 19, 2024, Judge Terry Means, also of the Fort Worth Division, made yet another finding that Mr. Castro brought a lawsuit that lacked personal jurisdiction….

The Court notices a pattern. Mr. Castro seems to pay no attention or care to where he files his lawsuits. Either he actively chooses to sue where he knows the Court lacks personal jurisdiction, or he fails to understand how jurisdiction and venue work, despite many orders informing him of the standard and explaining why he continuously falls short.

Given that Mr. Castro has a law degree, the Court would have hoped he learned how personal jurisdiction worked during his first-year coursework. Mr. Castro claims that he has "learned a hard legal lesson" about personal jurisdiction due to his many cases suffering the same fate, but it is not the Court's job to continue Mr. Castro's legal education here. Federal courts, particularly in the Fort Worth Division, are far too busy with meritorious lawsuits to entertain litigants "learning" how jurisdiction works through a repeat trial-and-error process.

By declaring Mr. Castro, a vexatious litigant and requiring him to obtain leave of court before filing suit in this district, the Court can help ensure Mr. Castro is filing his lawsuits in the right place, thus preventing continued overload of the Court's docket at his hands. Further, a review of Mr. Castro's other endeavors in federal court indicates Castro has been cautioned elsewhere regarding his inappropriate behavior. See, e.g., Castro v. Oliver (D.N.M. 2023) ("Having put this legal matter to rest, the Court concludes by noting that Castro's filing employs a tenor unfamiliar to this Judge and one that is out of step with practice in this district. The Court cautions Castro and requests that any future filings comport with decorum and the respect practitioners typically afford federal judges."); Castro v. Warner (S.D.W. Va. 2023) (observing that Castro's filings "contain numerous examples of clearly inappropriate attacks" and noting that "derisive commentary is of little value to the Court in resolving motions"). The Court notes similar behavior in this case. See ECF No. 45 at 2 (accusing opposing counsel of lying to the Court and engaging in deception as well as accusing the Court of not enforcing ethical rules).

Considering Mr. Castro's history of brazen, jurisdictionally improper lawsuits, his accusations and ad hominem attacks toward opposing counsel, and the Court's burden of having to continually reeducate him regarding the basics of venue and jurisdiction, the Court determines an adequate sanction for Mr. Castro is to have him declared a vexatious litigant and for him to obtain leave of court before filing any additional complaints in this district….

The court also concluded that in this case the court likewise lacked personal jurisdiction over the defendants, since their actions were not sufficiently closely linked to Texas (to oversimplify in some measure).