SHEETS
v.
CHARLOTTE COUNTY
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The court denied the plaintiff's motion to reinstate electronic filing access, finding no constitutional right to such access and that alternative filing methods are sufficient.
The plaintiff, a pro se litigant, filed an emergency motion to reinstate electronic filing access after the court discontinued its web portal. The pla…
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Before the Court is Plaintiff Andrew Bryant Sheets' Emergency Motion to Reinstate Electronic Filing Access. (Doc. 118.) [fn 1] For the reasons below, the motion is DENIED.
The Court currently operates a web portal that allows pro se litigants to file documents electronically. That service will end next week. Citing his “constitutional need for electronic filing access,” Plaintiff demands “an order
reinstating his ability to submit filings through the . . . Web Portal.” (Doc. 118 at 1.)
Plaintiff's inability to file electronically does not constitute a legal barrier to participation. He can file documents through the mail or by hand delivery to the clerk's office. That access is sufficient to alleviate any constitutional concerns. See, e.g., McNiece v. Town of Yankeetown, 817 F. App'x 842, 845 (11th Cir. 2020). “There is no constitutional right to electronic filing, and courts are permitted to manage access to electronic systems in the interest of administrative efficiency, consistency, and security." In re Vital Pharms., Inc., No. 22-17842-PDR, 2025 WL 1189882, at *9 (Bankr. S.D. Fla. Apr. 23, 2025).
The Court discontinued its web portal to realign resources and ensure continued efficiency. Plaintiff has not shown that this decision was unlawful or arbitrary. McNiece, 817 F. App'x at 845.
Plaintiff also asks the Court to “adopt a mailbox rule deeming mailing filings timely based on the . . . postmark date.” (Doc. 118 at 2-3.) But the “mailbox rule” is limited to “pro se prisoner[] filings.” Wilson v. Johnson, No. 2:23-CV-354-TFM-MU, 2024 WL 3297072, at *1 (S.D. Ala. July 3, 2024). Plaintiff offers no authority extending the mailbox rule to non-prisoners. Nor has he convinced the Court that such relief is necessary. Plaintiff can ask
that filings be emailed to him (as opposed to postmarked) and otherwise monitor the docket through PACER.
For these reasons, Plaintiffs Emergency Motion to Reinstate Electronic Filing Access (Doc. 118) is DENIED.
ORDERED in Fort Myers, Florida on July 28, 2025.
Kyle C. Dudek United States Magistrate Judge
[fn 1]: Unless otherwise indicated, all internal quotation marks, citations, case history, and alterations have been omitted in this and later citations.