SHEETS
v.
ANGELINI
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A pro se plaintiff incarcerated or civilly committed requested electronic filing (CM/ECF) system access to file documents in federal court. The court denied the request, holding that pro se litigants must demonstrate extenuating circumstances, including severe financial and physical barriers, verified and corroborated by supporting documentation, along with evidence of no history of judicial system abuse.
The court held that a pro se litigant must demonstrate extenuating circumstances to justify CM/ECF access, including both severe financial and physical barriers making it extraordinarily difficult to obtain postage and mail documents. The request must be verified under oath, corroborated by medical and other affidavits, and must include a complete disclosure of all prior pro se litigation and any history of frivolous claims, failure to prosecute, or sanctions.
“Even incarcerated or civilly committed pro se parties routinely litigate their matters by mail. So, to present a colorable request for CM/ECF access, a pro se litigant must show that "extenuating circumstances exist to justify waiving CM/ECF procedures."”
Establishes the legal standard that pro se litigants must meet to obtain CM/ECF access—mere incarceration is insufficient; extenuating circumstances are required.
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Join FLexlaw to unlock all legal intelligenceAndrew Bryant Sheets, proceeding pro se, filed a motion requesting permission to file papers via the court's CM/ECF electronic filing system. The cour…
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Pro se plaintiff Andrew Bryant Sheets requests permission to file papers via our CM/ECF system. But the system contains confidential and other sensitive information, and so access is generally restricted. See Administrative Procedures for Electronic Filing (Aug. 1, 2025) for the United States District Court, Middle District of Florida.
Even incarcerated or civilly committed pro se parties routinely litigate their matters by mail. So, to present a colorable request for CM/ECF access, a pro se litigant must show that "extenuating circumstances exist to justify waiving CM/ECF procedures." Huminski v. Vermont, No. 2:13-cv-692-FTM-29, 2014 WL 169848, *4 (M.D. Fla. Jan. 15, 2014); see also McMahon v. Cleveland Clinic Found. Police Dep't, 455 F. App'x 874, 878 (11th Cir. 2011) (affirming denial of CM/ECF access for pro se litigant because there was “no good cause under the circumstances of the case to authorize his access"). At a minimum, this would include both financial and physical barriers that make it extraordinarily difficult to acquire postage and submit envelopes to a mail carrier, and to otherwise deliver papers to the court.
The request would need to be verified (submitted under oath) and corroborated by affidavits from medical and other sources. Moreover, the applicant would need to demonstrate the absence of misuse of the judicial system by (1) identifying every state and federal case to which he or she is or was a pro se party; and (2) discussing the absence or presence of any adverse orders in those cases that dismissed any frivolous claims, dismissed any actions for failure to prosecute or to abide by court orders, or imposed any sanctions for such conduct such as a screening procedure before items would be accepted for filing.
For failing to meet this standard, the motion for CM/ECF access (Doc. 7) is
DENIED.
ORDERED on September 22, 2025
Sitter P. Mijell
NICHOLAS P. MIZELL
United States Magistrate Judge