In Re: Valerie Flores

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
_____________________________________________
IN RE: VALERIE FLORES,
1:26-pf-1 (BKS)
Respondent.
_____________________________________________
Hon. Brenda K. Sannes, Chief U.S. District Judge:
ORDER TO SHOW CAUSE
I. 	INTRODUCTION
On December 19, 2025, United States District Judge Glenn T. Suddaby issued a Text
Order in Flores v. Credit One Bank, No. 25-cv-00683 (GTS/MJK) (N.D.N.Y. filed Dec. 19,
2025), Dkt. No. 9, referring the plaintiff, Valerie Flores (named here as “Respondent”), to the
undersigned for consideration of whether an order directing Flores to show cause why she should
not be enjoined from filing any new actions in the Northern District of New York as a pro se
litigant, without prior permission of the Chief Judge. For the reasons that follow, the Court
orders Respondent to show cause why she should not be enjoined from filing any civil action pro
se in this District without prior leave of the Chief Judge or his or her designee.
II. 	BACKGROUND
Since August 2023, Respondent has filed 33 actions pro se in the Northern District of
New York: Flores v. Meigs, No. 23-cv-00979 (filed Aug. 11, 2023); Flores v. SSM Health, et al.,
No. 23-cv-00980 (filed Aug. 11, 2023); Flores v. Gorman & Co., No. 23-cv-01023 (filed Aug.
21, 2023); Flores v. California Highway Patrol, No. 24-cv-01229 (filed Oct. 7, 2024); Flores v.
Peterson, No. 24-cv-01231 (filed Oct. 7, 2024); Flores v. Comm’r of Social Security, No. 25-mc-
00006 (filed Mar. 26, 2025); Flores v. Van Galder Coach USA Bus Co., No. 25cv00684 (filed
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May 29, 2025); Flores v. Credit One Bank, No. 25-cv-00683 (filed May 28, 2025); Flores v.
Vang, No. 25-cv-01733 (filed Dec. 10, 2025); Flores v. Liberty Mutual Ins., No. 25-cv-01730
(filed Dec. 10, 2025); Flores v. Carry on Trailer, No. 25-cv-01731 (filed Dec. 10, 2025); Flores
v. Cornerstone Manor, No. 25-cv-01744 (filed Dec. 14, 2025); Flores v. Great Deals on Wheels,
No. 25-cv-01745 (filed Dec. 14, 2025); Flores v. Wells Fargo, No. 25-cv-01755 (filed Dec. 14,
2025); Flores v. Delaware North, No. 25-cv-01757 (filed Dec. 14, 2025); Flores v. The Glover
House, No. 25-cv-01760 (filed Dec. 14, 2025); Flores v. Davis, No. 25-cv-01758 (filed Dec. 14,
2025); Flores v. Hoye, et al., No. 25-cv-01743 (filed Dec. 14, 2025); Flores v. CA Cares, No.
25-cv-01761 (filed Dec. 15, 2025); Flores v. Stephani, No. 25-cv-01824 (filed Dec. 26, 2025);
Flores v. Northshore Univ. Health Sys./Northwest Comm. Hosp., No. 25-cv-01819 (filed Dec.
26, 2025); Flores v. City of Pittsburgh, No. 25-cv-01823 (filed Dec. 25, 2025); Flores v. Dane
Cnty. Human Servs., No. 25-cv-01831 (filed Dec. 25, 2025); Flores v. Lester Smith, No. 25-cv-
01838 (filed Dec. 26, 2025); Flores v. Car Revolution, No. 25-cv-01820 (filed Dec. 27, 2025);
Flores v. Meyer, No. 25-cv-01829 (filed Dec. 27, 2025); Flores v. Carvana, No. 25-cv-01826
(filed Dec. 28, 2026); Flores v. Thomas, No. 25-cv-01834 (filed Dec. 28, 2025); Flores v. Kropp,
No. 25-cv-01835 (filed Dec. 30, 2025); Flores v. Lettman, No. 25-cv-01833 (filed Dec. 31,
2025); Flores v. Williams Court, No. 26-cv-00015 (filed Jan. 6, 2026); Flores v. Topp, No. 26-
cv-00056 (filed Jan. 12, 2026); and Flores v.Ward, No. 25-cv-00061 (filed Jan. 12, 2026).
As to the disposition of the above cases, 11 have been transferred to other district courts
on the grounds that venue in the Northern District of New York was improper: Flores v. Meigs,
No. 23-cv-00979, Flores v. SSM Health, No. 23-cv-00980, Flores v. Gorman & Company, No.
23-cv-01023, Flores v. Peterson, No. 24-cv-01231, and Flores v. Van Galder Coach USA Bus
Co., No. 25-cv-00684; and Flores v. Dane County Human Services, No. 25-cv-01831 were
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transferred to the Western District of Wisconsin; Flores v. California Highway Patrol, et al., No.
24-cv-01229, was transferred to the Central District of California; Flores v. Cornerstone Manor,
et al., No. 25-cv-01744 was transferred to the Western District of New York; Flores v. The
Glover House, No. 25-cv-01760 was transferred to the District of Columbia District Court;
Flores v. Davis, No. 25-cv-01758 was transferred to the Southern District of New York; and
Flores v. Stephani, et al., No. 25-cv-01824 was transferred to the Eastern District of Wisconsin.
Flores v. Commissioner of Social Security, No. 25-mc-00006, was dismissed for lack of subject
matter jurisdiction; Flores v. Credit One Bank, et al., No. 25-cv-00683, was dismissed with leave
to file an amended complaint; Report-Recommendations recommending dismissal with leave to
amend are pending in Flores v. Wells Fargo, No. 25-cv-01755 and Flores v. Williams Court, No.
26-cv-00015; and Flores v. CA Cares, et al., No. 25-cv-01761, and Flores v. Lester Smith, et al.,
No. 25-cv-0183, were administratively closed pending payment of the filing fee or the filing of
an application to proceed in forma pauperis (“IFP”). The remaining cases are pending before the
assigned magistrate judge for determination of Respondent’s application for IFP status and initial
review.
Respondent has also filed multiple cases in other districts, including, among others,1 the
Western District of Wisconsin, see, e.g., Flores v. Stonehouse Development, No. 21-cv-00466
(W.D. Wis. filed July 22, 2021); Flores v. Stonehouse Development, No. 21-cv-00529 (W.D.
Wis. filed Aug. 20, 2021)); Flores v. City of Madison, No. 21-cv-00546 (W.D. Wis. filed Aug.
26, 2021), and the District of Columbia, see, e.g., Flores v. Dane Cnty., et al., No. 23-cv-00020
(D.D.C. filed Jan. 3, 2023); Flores v. Northwest Comm. Hosp., No. 23-cv-02867 (D.D.C. filed
1 The Judiciary’s Public Access to Court Records (“PACER”) system, see https://pacer.uscourts.gov/ (last visited
Jan. 20, 2026), indicates that Respondent has also filed case in, or has had cases transferred to, the Central District of
California, the Middle District of Florida, the Southern and Western Districts of New York, and the Eastern District
of Wisconsin.
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Sep. 11, 2023); Flores v. California Highway Patrol, et al., No. 24-cv-00914 (D.D.C. filed Mar.
20, 2024); Flores v. Olson, No. 24-cv-01010 (D.D.C. filed Apr. 5, 2024). However, in 2024,
both districts revoked Respondent’s in forma pauperis status and barred Respondent from filing
further cases without prepaying the filing fee. Flores v. Progressive Ins., No. 23-cv-00398 (W.D.
Wis. Apr. 19, 2024), Dkt. No. 23 (Bar Order); Flores v. Olson, 24-cv-01010 (D.D.C. Aug. 1,
2024), Dkt. No. 4, at 1 (Bar Order). Specifically, the Western District of Wisconsin sanctioned
Respondent for “abus[ing] the judicial process with frivolous litigation” and barred Respondent
from bringing new lawsuits without first prepaying the entire filing fee. Flores v. Progressive
Ins., No. 23-cv-00398 (W.D. Wis. Apr. 19, 2024), Dkt. No. 23. The court explained that of the
13 lawsuits Respondent had filed “[o]ver the last three years,” 12 had been dismissed at the
screening stage for “failing to state a federal claim, failing to meet the requirements for diversity
jurisdiction, or being duplicative of another of her complaints.” Id., Dkt. No. 23, at 7. In its Bar
Order, the district court for the District of Columbia found that in “a year and a half, Flores ha[d]
filed 38 actions,” 21 of which had been dismissed “largely for failure to state a claim and for
failure to comply with the Court’s directives,” that Respondent had been “repeatedly forewarned
that she may, in the future, be declared a vexatious litigant,” that Respondent had filed “at least
22 matters in other federal courts, and similarly, [that] most of them also failed to survive the
screening process,” and concluded that “Flores’s repeated filing of meritless complaints
demonstrate[d] a persistent and ongoing pattern of filing frequent and duplicative lawsuits,
overburdening the Court” and warranting the sanction of barring Respondent from filing any
further actions without prepaying the filing fee. Flores v. Olson, 24-cv-01010 (D.D.C. Aug. 1,
2024), Dkt. No. 4, at 1–2.
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III. 	DISCUSSION
A. 	Relevant Law
It is well settled that “[a] district court may, in its discretion, impose sanctions against
litigants who abuse the judicial process.” Shafii v. British Airways, PLC, 83 F.3d 566, 571 (2d
Cir. 1996). Where a litigant persists in the filing of vexatious and frivolous suits, it may be
appropriate to place certain limitations on the litigant’s future access to the courts. See Hong Mai
Sa v. Doe, 406 F.3d 155, 158 (2d Cir. 2005) (citing Iwachiw v. New York State Dep’t of Motor
Vehicles, 396 F.3d 525, 528 (2d Cir. 2005)); see also Shafii, 83 F.3d at 571 (“The filing of
repetitive and frivolous suits constitutes the type of abuse for which an injunction forbidding
further litigation may be an appropriate sanction.”). The Second Circuit has instructed that courts
must consider the following factors in deciding whether to impose a pre-filing injunction:
(1) the litigant’s history of litigation and in particular whether it
entailed 	vexatious, 	harassing 	or 	duplicative 	lawsuits; 	(2) 	the
litigant’s motive in pursuing the litigation, e.g., does the litigant
have an objective good faith expectation of prevailing?; (3) whether
the litigant is represented by counsel; (4) whether the litigant has
caused 	needless 	expense 	to 	other 	parties 	or 	has 	posed 	an
unnecessary burden on the courts and their personnel; and (5)
whether other sanctions would be adequate to protect the courts and
other parties.
Eliahu v. Jewish Agency for Israel, 919 F.3d 709, 714 (2d Cir. 2019) (quoting Iwachiw, 396 F.3d
at 528).
B. 	Analysis
Since August 2023, Respondent, acting pro se, has filed 33 actions naming approximately
90 different defendants; Respondent has filed 25 actions in just over one month and on
December 14, 2025, filed 7 cases in one day. As outlined above, of the 16 actions that have
undergone an initial review, all have been transferred, dismissed, or recommended for dismissal.
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The Court therefore has little difficulty finding that Respondent’s conduct in filing so many cases
in such a short period of time can only be for purposes of vexation and harassment. Further, there
is reason to believe that Respondent is filing these actions in this District in an attempt to
circumvent the Bar Orders issued in the Western District of Wisconsin and the District of
Columbia. First, Respondent filed 30 of her 33 actions in this Distrct after the issuance of the Bar
Orders. Second, at least three of Respondent’s recently-filed actions named defendants residing
in Wisconsin and have been transferred to the Western District of Wisconsin, see Flores v.
Peterson, No. 24-cv-01231, Dkt. No. 4; Flores v. Van Galder Coach USA Bus Co., No. 25-cv-
00684, Dkt. No. 7; Flores v. Dane Cnty. Human Svcs., No. 25-cv-01831, Dkt. No. 9, and at least
one of those actions named a defendant who was alleged to be from the District of Columbia and
has also been transferred on grounds of improper venue, see Flores v. The Glover House, No. 25-
cv-01760, Dkt. No. 5. Finally, as Respondent is well aware of the requirements for venue in the
Northern District of New York as they were discussed at length in the orders transferring the first
three cases she filed this District, see Flores v. Meigs, No. 23-cv-00979, Dkt. No. 4; Flores v.
SSM Health, No. 23-cv-00980, Dkt. No. 6; Flores v. Gorman & Co., No. 23-cv-01023, Dkt. No.
4, the Court finds Respondent’s motive in pursuing litigation in this District is not in good faith
but in an effort to evade the Bar Orders imposed in the Western District of Wisconsin and the
District of Columbia. See United States ex rel. Wolf v. United States, No. 19-cv-2100, 2019 WL
1865202, at *2 (E.D.N.Y. Apr. 23, 2019) (finding that “since the proper venue” for the plaintiffs’
claims was in the Eastern District of New York, where the plaintiffs were subject to a bar order,
the plaintiffs’ “filing of such claims in other jurisdictions would only be done in bad faith and in
an effort to circumvent the bar order”). Thus, the Court concludes that Respondent’s conduct in
filing of numerous actions is not only vexatious in nature but is not done in good faith.
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Although Respondent is not represented by counsel and has not, to date, caused needless
expense to other parties as the courts in this District have dismissed or transferred her actions
prior to the appearance of other parties, Respondent has caused an unnecessary burden on the
Northern District of New York and its personnel. In all, Respondent has filed actions before
seven district court judges and six magistrate judges, and management of those cases has
required the extensive involvement of both Clerk’s Office and Chambers’ staff.
In light of the Respondent’s ongoing efforts to file numerous lawsuits, even after having
been subject to the sanction of being required to pay the filing fee in other districts, the Court
finds no sanction other than an order barring Respondent from filing future actions pro se,
without prior approval, would offer defendants or the Court adequate protection. See Eliahu, 919
F.3d at 715 (noting that although the plaintiffs had the resources to pay filing fees, “the record
demonstrat[ed] that monetary sanctions are unlikely to dissuade them from continuing their
litigation campaign”). Therefore, after carefully reviewing the record, the Court concludes that,
unless Respondent shows cause otherwise, Respondent shall be enjoined from filing any civil
action pro se in this District without prior leave of the Chief Judge or his or her designee.2
Notwithstanding the overwhelming support for a pre-filing injunction of this kind, fairness
dictates that Respondent be given notice and an opportunity to be heard. See Iwachiw, 396 F.3d
at 529. As a result, Respondent shall have fourteen (14) days from the date of this Order to show
cause, in writing, why she should not be from filing any civil action pro se in this District
without prior leave of the Chief Judge or his or her designee.
2 A pre-filing injunction would not apply to previously filed actions.
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IV. 	CONCLUSION
ACCORDINGLY, it is
ORDERED that Respondent Valerie Flores shall, within FOURTEEN (14) DAYS of
the date of this Order, show cause, in writing, why she should not be barred from filing any civil
action pro se without prior leave of the Chief Judge or his or her designee;3 and it is further
ORDERED that, if Respondent does not fully comply with this Order, the Court will
issue a subsequent order, without further explanation, permanently so enjoining Respondent; and
it is further
ORDERED that the Clerk shall mail a copy of this Order to Show Cause to Respondent
by regular and certified mail.
IT IS SO ORDERED.
Dated: January 20, 2026
3 This injunction would apply to, among other things, continued filings by Respondent as a pro se plaintiff in any
action filed by her in state court removed to this Court or filed by her in another United States District Court and
transferred to this Court. See Sassower v. Starr, 338 B.R. 212, 218-19 & n.1 (S.D.N.Y. Bankr. 2006) (recognizing
validity of pre-filing injunction expressly applying to actions removed from state courts to the Southern District of
New York); Jenkins v. Kerry, 928 F. Supp. 2d 122, 126 (D.D.C. 2013) (noting that Southern District of Florida
would apply its pre-filing injunction to case that was transferred there from the District for the District of
Columbia); Petrols v. Boos, No. 10-cv-0777, 2012 WL 1193982, at *1, n.3, 2012 U.S. Dist. LEXIS 49785, at *2, n.3
(N.D. W. Va. Apr. 10, 2012) (“This pre-filing injunction does not preclude the plaintiff from filing an action in state
court, but it does apply to cases filed in state court that are removed to this Court.”); Kissi v. Pramco, II, LLC, No.
09-cv-0267, 2009 WL 8636986, at *1, 2009 U.S. Dist. LEXIS 61425, at *2 (D. Md. Feb. 12, 2009) (applying
District of Maryland’s pre-filing injunction to case that had been transferred from the District of Delaware).
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