Background
Mischa Adorare moved into a townhome owned and operated by Spillman Ranch Homes in September 2022. After a series of disputes, a Travis County court ordered her eviction in July 2024. Adorare filed numerous complaints and lawsuits in Texas courts and administrative agencies concerning alleged harms during her tenancy.
In December 2023, Adorare sued Spillman in the Western District of Texas, alleging failure to accommodate under the Fair Housing Act, discrimination based on race, gender, and disability, and retaliation. Following extensive motion practice, the district court granted summary judgment to Spillman, denied Adorare’s motion for summary judgment, and required her to obtain leave before filing additional motions. It later denied her motion to set aside the judgment and her motion to recuse the district judge.
The Court’s Holding
The Fifth Circuit affirmed. Reviewing summary judgment de novo, the court concluded that no genuine dispute of material fact made summary judgment improper. Because the claims presented no triable factual dispute, resolving them at summary judgment also did not violate Adorare’s Seventh Amendment right to a jury trial.
The court further held that the district court did not abuse its discretion in denying reconsideration under either Rule 59(e) or Rule 60(b), imposing the leave-to-file requirement as an exercise of its inherent docket-management authority, or denying recusal. Adorare forfeited her constitutional challenges to the filing restriction by raising them for the first time on appeal.
Key Takeaways
- Summary judgment does not violate the Seventh Amendment when no genuine dispute of material fact requires a jury trial.
- A district court may require leave before accepting additional motions as part of its broad inherent authority to manage its docket.
- Constitutional objections raised for the first time on appeal are generally forfeited, while denials of reconsideration and recusal are reviewed for abuse of discretion.
Why It Matters
The unpublished decision reinforces that Fair Housing Act plaintiffs must produce evidence creating a genuine factual dispute to proceed to trial; invoking the Seventh Amendment does not independently prevent summary judgment. It also confirms the substantial discretion district courts possess when addressing repetitive motion practice and recusal requests.