JOSHUA CROCKETT
v.
ORANGE COUNTY BOARD OF COUNTY COMMISSIONERS
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The court denied the pro se plaintiff's motion for CM/ECF access because it failed to comply with local rules and lacked a showing of good cause or extenuating circumstances. However, the court granted permission for the plaintiff to receive electronic notifications via email.
[1] A pro se litigant seeking electronic filing access under CM/ECF must comply with local rule conferral requirements and demonstrate good cause or extenuating circumstances…
[2] Although CM/ECF electronic filing access may be denied to pro se litigants, a court may in its discretion permit electronic notice service by email to a pro se party.
Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“[W]hile an unrepresented individual may obtain the Court's permission to file his submissions electronically using the CM/ECF system, such authorization is typically denied unless the pro se party makes a showing of good cause or extenuating circumstances justifying such relief.”
Court explaining the standard for CM/ECF access by pro se litigants.
Plaintiff, proceeding pro se, moved for access to the Court's CM/ECF electronic docketing system. He cited prejudice due to living in Arizona, mailing…
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Case No: 6:24-cv-1234-AGM-LHP
(And Direction to Clerk of Court)
This cause came on for consideration without oral argument on the following motion filed herein:
MOTION: PLAINTIFF'S MOTION FOR CM/ECF ACCESS (Doc. No. 40)
FILED: July 31, 2025
THEREON it is ORDERED that the motion is DENIED. Plaintiff Joshua Crockett, proceeding pro se, requests access to the Court's CM/ECF electronic docketing system. Doc. No. 40. Upon review, the motion is due to be denied for two reasons.
First, the motion fails to comply with the conferral requirements of Local Rule 3.01(g)(3). Second, "[w]hile an unrepresented individual may obtain the Court's permission to file his submissions electronically using the CM/ECF system, such authorization is typically denied unless the pro se party makes a showing of good cause or extenuating circumstances justifying such relief.” Hooker v. Wilkie, No. 8:20-cv-1248-T-02CPT, 2020 WL 6947482, at *1 (M.D. Fla. June 4, 2020) (citations omitted).
Here, Plaintiff makes no such showing. The basis for Plaintiff's request is that he suffers prejudice as a pro se litigant through "unnecessary delays and excessive costs" due to his living in Arizona, the mailing of his filings, and the loss of access to the Court's web portal, and that Defendants have engaged in various procedural violations. Doc. No. 40, at 1-4. With respect to the concerns regarding costs and delays, these concerns are common to all pro se litigants who file paper documents, and if these burdens were enough to justify CM/ECF access, the exception would swallow the rule. See, e.g., Pouyeh v. Pub. Health Tr. of Jackson Health Sys., No. 24-10988, 2025 WL 2319399, at *6–7 (11th Cir. Aug. 12, 2025) (denial of CM/ECF access to plaintiff living overseas did not violate right of access to the courts because right of access is “neither absolute nor conditional"); Clifft v. Sch. Dist. of Lee Cnty., No. 2:25-cv-345-JES-DNF, 2025 WL 3012038, at *2 (M.D. Fla. Oct. 28, 2025), reconsideration denied, No. 2:25-cv-345-JES-DNF, 2025 WL 3080533 (M.D.
Fla. Nov. 4, 2025) (affirming denial of CM/ECF access to pro se litigants, finding that unpredictable delays and mail delivery risks, complexity of the case, and inability to obtain legal counsel did not rise to the level necessary to justify CM/ECF access); Sheets v. Pribble, No. 2:24-cv-958-JES-KCD, 2025 WL 2106679, at *1 (M.D. Fla. July 28, 2025) (denying motion for CM/ECF access and explaining that discontinuation of the Court's web portal “does not constitute a legal barrier to participation" given that a litigant may still "file documents through the mail"). In addition, the Federal Rules of Civil Procedure already account for paper filings and add three (3) days to a party's deadline when service is made by mail. See Fed. R. Civ. P. 6(d). The concerns regarding Defendant's purported procedural violations can also be addressed either sua sponte by the Court or by the filing of an appropriate motion.
Accordingly, Plaintiff's motion (Doc. No. 40) is DENIED. That said, “the Court in its discretion may grant a pro se party permission to receive electronic notifications." See Moore v. Adventist Health Sys. Sunbelt Healthcare Corp., No. 6:23- cv-1163-PGB-DCI, 2023 WL 4947933, at *1 (M.D. Fla. Aug. 3, 2023). The Court finds it appropriate to exercise such discretion here. See id.; see also Cromity v. City of Orlando, No. 6:24-cv-1688-CEM-DCI, 2025 WL 435901, at *1 (allowing service of court documents on pro se party by email); Wilkins v. RCI, LLC, No. 6:23-cv-849-PGB- EJK, 2023 WL 3453560, at *1 (M.D. Fla. May 15, 2023) (same). Therefore, the Clerk of Court is DIRECTED to add Plaintiff's email address to CM/ECF,
[email protected], and ensure that Plaintiff receive Notices of Electronic Filings.
DONE and ORDERED in Orlando, Florida on December 8, 2025.
Uslis Henan Price
LESLIE HOFFMAN PRICE
UNITED STATES MAGISTRATE JUDGE
Copies furnished to: Counsel of Record Unrepresented Parties
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…(Fla. 2009) (initial state postconviction proceeding); Hutchinson v. State, 243 So. 3d 880 (Fla. 2018) (successive state proceeding); Hutchinson v. State, 343 So. 3d 50 (Fla. 2022) (successive state proceeding); Hutchinson v. State, No. SC2025-0497, 2025 WL 2. For all three children, the court found that the youth and prior-violent-felony aggravators applied. And as for Geoffrey, the court ruled that his murder was heinous, atrocious, and cruel. - 6 - ---PAGE 6--- 1155717 (Fla. Apr. 21, 2025) (successi…
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Crockett v. Orange Cnty. Bd. of Cnty. Comm'rs, 2025 WL 2 (M.D. Fla. 2025)…le his submissions electronically using the CM/ECF system, such authorization is typically denied unless the pro se party makes a showing of good cause or extenuating circumstances justifying such relief.” Hooker v. Wilkie, No. 8:20-cv-1248-T-02CPT, 2020 WL 6947482, at *1 (M.D. Fla. June 4, 2020) (citations omitted). Here, Plaintiff makes no such showing. The basis for Plaintiff's request is that he suffers prejudice as a pro se litigant through "unnecessary delays and excessive costs" due to his living in Ar…
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Ligieri v. Amazon.com, Inc. (M.D. Fla. 2025)…le his submissions electronically using the CM/ECF system, such authorization is typically denied unless the pro se party makes a showing of good cause or extenuating circumstances justifying such relief.” Hooker v. Wilkie, No. 8:20-cv-1248-T-02CPT, 2020 WL 6947482, at *1 (M.D. Fla. June 4, 2020) (citations ¹ Even if there were an operative complaint, it is unclear why leave of Court would be required. -2- ---PAGE 3--- Case 6:25-cv-02119-AGM-LHP Document 26 Filed 12/19/25 Page 3 of 3 PageID 727 omitted). H…
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- Nathansen v. City of Ocala (M.D. Fla. 2026)
- Crockett v. Orange Cnty. Bd. of Cnty. Comm'rs, 2025 WL 2 (M.D. Fla. 2025)
- Ryals v. United States Attorney General, 2023 WL 3453560 (M.D. Fla. 2025)
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