Daria v. Sapient Corp

Background

Haley Daria filed the lawsuit without a lawyer against Sapient Corporation, as acquirer of World Wide Web Associates, LLC, and Rachel Adamski, Robin DeShayes, Robert G. Klein, Rancho San Roque, David La Fitte, and Mack Staton. The defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(5) and 12(b)(6). The same defendants, except Mack Staton, also moved for a declaration that Daria was a vexatious litigant and for a prefiling order.

The dispute concerned Daria’s interest in common stock of World Wide Web Associates and a 2007 merger. The opinion states that Daria had earlier litigation and settlement involving the company and that she received $50,000 in connection with the 2007 settlement. That settlement included broad language releasing disputes with the company and specified related people and entities.

Daria had previously filed several state and federal lawsuits concerning the same general events. In this case, she alleged duress, coercion, fraud, bait-and-switch tactics, and violations of the Racketeer Influenced and Corrupt Organizations Act. The opinion also describes allegations concerning a supposed additional contract that neither side could produce.

Dismissal ruling

The court held that the complaint did not state a claim for relief. It found that the pleading did not meet the ordinary federal requirement for a clear statement of a claim, the heightened requirement for fraud allegations, or the pleading standards established by Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal. The court also described the complaint as perplexing, rambling, and filled with accusations, unrelated points, and citations.

The court further held that the case was barred by claim preclusion, the rule that generally prevents a party from relitigating matters that were already resolved in earlier litigation. The court stated that Daria could not start over by asserting a new theory of relief concerning the same dispute. The defendants’ motion to dismiss was GRANTED, and the court dismissed the civil action.

Prefiling order

A prefiling order requires a litigant to obtain court screening before filing certain future lawsuits. The court found that Daria had notice of the request, had an opportunity to oppose it, and had argued at a hearing. It also found an adequate record based on her earlier state and federal lawsuits and made findings that her repeated lawsuits were duplicative, unsuccessful, and abusive of defendants’ and the court’s time and resources.

The court narrowly limited the order to future filings that would reopen litigation based on facts or issues decided in earlier lawsuits involving the same or nearly the same group of defendants. The motion for a prefiling order was also GRANTED.

The clerk was instructed not to automatically accept future filings by Daria, whether filed through a lawyer or by Daria herself, if they fall within the order’s specified categories. Those categories include filings against Sapient Corporation and specified related companies, officers, directors, employees, and spouses; filings against attorneys or law firms that represented parties in this or earlier litigation; filings against defendants or other parties named in related federal actions; matters concerning World Wide Web Associates’ acquisition and merger or the 2000 and 2007 settlements; matters arising from Daria’s interest in that acquisition and merger or Sapient Corporation’s role as acquirer; lawsuits concerning those interests; and attempts to relitigate issues Daria previously raised.