HARDY
v.
STRAYER UNIVERSITY, LLC
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Plaintiff Hardy, a pro se litigant in a case against Strayer University and Karl McDonnell, sought access to the Court's CM/ECF electronic filing system. The District Court, through a magistrate judge, denied the motion because the filing failed to comply with Local Rule 1.08 formatting requirements and because pro se litigants are generally denied CM/ECF access absent extenuating circumstances.
The motion for CM/ECF access is denied for two independent reasons: (1) the motion failed to comply with Local Rule 1.08 formatting requirements, and (2) pro se litigants are generally denied CM/ECF access absent extenuating circumstances, none of which were demonstrated here. The Court noted that the Plaintiff may use PACER to access case documents.
[1] A pro se litigant is generally denied access to the Court's case management/electronic filing system (CM/ECF) unless extenuating circumstances justify waiving CM/ECF proc…
[2] Filings submitted to the court must comply with local rules regarding formatting, including typewritten requirements and double-spacing.
Previewing 2 of 4 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“[p]ro se litigants are generally denied access to electronic filing unless extenuating circumstances exist to justify waiving CM/ECF procedures.”
Establishes the governing legal standard for denying CM/ECF access to pro se litigants absent extraordinary circumstances.
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Join FLexlaw to unlock all legal intelligencePlaintiff Lenorris E. Hardy, Sr., proceeding pro se, filed a motion seeking access to the Court's case management/electronic filing (CM/ECF) system. T…
The full statement of facts, procedural history, and disposition for this case are member content.
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This matter is before the Court without oral argument on Plaintiff's Motion for Access to CM/ECF Case Management/Electronic Filing (Dkt. 20), filed August 7, 2025. The motion has been referred to a magistrate judge for consideration. Defendants need not respond.
The motion is denied for two reasons. First, all pleadings, motions, and other papers filed in this Court must comply with the requirements of Local Rule 1.08, unless otherwise modified by a court order. That rule requires filings to be typewritten papers, using certain typefaces and sizes. See Local Rule 1.08(a)–(b). The rule also requires the use of double-spacing for a filing's main text. See
id. 1.08(a). The motion does not comply with these requirements and is therefore due to be denied.
Second, although Plaintiff may have been granted access to the Court's case management/electronic filing system in a prior matter,¹ "[p]ro se litigants are generally denied access to electronic filing unless extenuating circumstances exist to justify waiving CM/ECF procedures.” Huminski v. Vermont, No. 2:13-cv-692, 2014 WL 169848, *4 (M.D. Fla. Jan. 15, 2014); see also McMahon v. Cleveland Clinic Found. Police Dep't, 455 F. App'x 874, 878 (11th Cir. 2011) (affirming denial of CM/ECF access for pro se litigants). No extenuating circumstances have been shown here. To the extent Plaintiff believes electronic filing will help him access documents in the case, he may use PACER to obtain filings.
Accordingly, it is ORDERED that Plaintiff's Motion for Access to CM/ECF Case Management/Electronic Filing (Dkt. 20) is
DENIED.
DONE and ORDERED in Orlando, Florida, on August 13, 2025.
Raut Norway
ROBERT M. NORWAY
United States Magistrate Judge
Copies to: Lenorris E. Hardy, Sr. 125 East Pine Street, Apt. 1107 Orlando, Florida 32801 Counsel of Record
[fn 1]: The web portal used previously by Plaintiff is no longer used by the Clerk of Court as the emergency that required it, the COVID pandemic, has passed. See Web Portal, https://apps.flmd.uscourts. gov/cmecf/filings.cfm ("Effective Friday, August 1, litigants without lawyers will not be permitted to submit filings through the court's web portal.").
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