Mphasis Corporation v. Rojas
- Jesse Furman
- 1:25-cv-03175
- U.S. District Court · Southern District of New York
- 3
Mphasis v. Rojas: Judge Wang struck eight filings, imposed $30 in sanctions, and extended the filing restriction through December 1, 2025.
Albert Rojas, who must pay $30 and is subject to an extended filing restriction; the Clerk of Court, which is to receive the payment.
What happened
In Mphasis Corporation v. Albert Rojas, the court addressed eight filings Albert Rojas made after earlier orders restricted him from filing papers unless the court directed him to do so.
The court struck filings 474 and 476 but imposed no monetary penalty for them because they were filed on the same day the latest restriction took effect. It struck six later filings and imposed a $5 penalty for each, totaling $30.
Judge Wang extended the filing restriction through December 1, 2025, ordered the $30 paid to the Clerk of Court by that date, and allowed Rojas to make one filing objecting to the order. Other filings or objections before December 1 could be struck and could result in additional penalties or loss of electronic filing privileges.
The detailed version
- Mphasis Corporation v. Rojas · No. 1:25-cv-03175
- Jesse Furman
- Nov. 5, 2025
Background
The court said Albert Rojas had made eight filings—ECF Nos. 474, 476, 477, 478, 479, 480, 481, and 483—between October 22 and November 5, 2025, in violation of court orders restricting his filings. The court had previously directed Rojas to make no further filings except as directed, extended that restriction several times, and warned him that violations could result in a $5 monetary sanction per filing.
A filing injunction is a court order restricting a party's ability to submit filings. The latest filing injunction was entered on October 22 and was in effect through November 10. The court stated that filings 474 and 476 were frivolous and duplicative, and that both concerned the plaintiff's memorandum supporting a motion for a temporary restraining order. The opinion also stated that the temporary restraining order had later been replaced by a preliminary injunction that remained in effect.
Court's Analysis
The court did not impose monetary sanctions for filings 474 and 476 because the earlier filing injunction had expired and the latest injunction was entered on the afternoon of October 22, the day those filings were submitted. The court nevertheless struck both filings.
The court found that Rojas should reasonably have known the filing restriction had been extended when he filed ECF Nos. 477, 478, and 479 on October 23, ECF Nos. 480 and 481 on October 30, and ECF No. 483 on November 5. It further found that another warning would not be enough to deter additional violations. The court therefore imposed a $5 sanction for each of those six filings.
Ruling
The court struck ECF Nos. 474, 476, 477, 478, 479, 480, 481, and 483. It sanctioned Rojas $5 for each of the six filings numbered 477 through 481 and 483, for a total of $30 payable to the Clerk of Court by December 1, 2025.
Judge Ona T. Wang also extended the filing injunction through December 1, 2025. Rojas may make one filing to object to the order. The order states that any other filings or objections before December 1 will be struck, will result in further $5 monetary sanctions per filing, and may lead to loss of electronic filing privileges.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.