Justin Ringgold-Lockhart v. County of Los Angeles

This appeal requires us to consider the limits of a federal court’s authority to impose pre-filing restrictions against so-called vexatious litigants. The case arises from one of many episodes in a legal saga involving Nina Ringgold and the Los An-geles Probate Court. Ringgold brought a federal lawsuit challenging the Probate Court’s authority to remove her as a trustee of the Aubry Family Trust. The district court dismissed the suit in a series of rulings, culminating in an order declaring Ringgold and co-plaintiff, Justin Ringgold-Lockhart, vexatious litigants. Ringgold and Ringgold-Lockhart appeal the vexatious litigant order. We reverse.

I.

Ringgold, an attorney, is a former trustee of the Aubry Family Trust (“the Trust”). According to her complaint, the Trust was established after the Aubry family was excluded from purchasing a home in a white Los Angeles neighborhood by race-based restrictive covenants. The Trust’s purpose was to benefit and empower the African-American community of South Central Los Angeles by providing for future generations. After Robert Au-bry died in 2002, Ringgold and another individual became trustees. For reasons not entirely clear, the…