## Facts

- Vince Camastro, acting pro se, disputed a decision by the West Virginia Alcoholic Beverage Control Commission (the Commission) affecting his business.
- After the Commission’s decision, Camastro filed a civil action against the Commission and additional defendants connected to the dispute.
- Camastro named at least one defendant who was deceased and another defendant who was a former mayor of Wheeling, West Virginia who had been out of office for several years.
- Before this case, Camastro had filed 13 separate lawsuits against the Commission raising similar or identical claims and issues.
- Prior efforts to curb Camastro’s filings had included a monetary sanction and a narrowly tailored pre-filing injunction, but those measures did not stop further related lawsuits.
- In this case, the Commission requested that the court sanction Camastro again.
- Instead of immediately imposing a new sanction, the court ordered Camastro to show cause why he should not be enjoined from filing additional lawsuits related to the same dispute.
- The court held a hearing on the show-cause order and then issued its decision.

## Issues

1. Whether the court should enjoin Camastro from filing additional lawsuits related to the Commission and the underlying dispute, given his history of repetitive and harassing litigation and the failure of prior sanctions and a narrower filing restriction.

## Decision

- The court entered a pre-filing injunction restricting Camastro from filing additional lawsuits related to the Commission dispute without first meeting court-imposed conditions.
- The court acted after giving Camastro notice and an opportunity to be heard through the show-cause procedure and a hearing.
- The court addressed the Commission’s request for further sanctions by using a filing restriction aimed at preventing new, duplicative, or harassing suits tied to the same subject matter.

## Legal Principles

- Federal courts have authority to protect their dockets and litigants from repetitive, harassing, or bad-faith filings by imposing filing restrictions on vexatious litigants.
- Before imposing a pre-filing injunction, a court should provide notice and an opportunity to be heard.
- In deciding whether to impose a filing injunction, courts consider factors such as the litigant’s history of repetitive litigation, the litigant’s purpose or good-faith basis, the burden on courts and parties, and whether lesser measures have been ineffective.
- Any pre-filing injunction must be narrowly tailored to the specific pattern of abusive filings, including limits tied to the subject matter or the parties involved rather than a blanket bar on all filings.

## Conclusion

In Camastro v. West Virginia Alcoholic Beverage Control Commission, the court responded to a long pattern of repetitive pro se lawsuits—13 prior actions raising similar or identical issues, including suits naming a deceased person and an official long out of office—by issuing a tailored pre-filing injunction after a show-cause order and hearing, concluding that prior monetary sanctions and a narrower filing restriction had not stopped further related litigation.


Camastro v. West Virginia Alcoholic Beverage Control Commission, 2015 WL 729665 (2015)