The U.S. Court of Appeals for the Eleventh Circuit affirmed a district court's dismissal with prejudice of a pro se plaintiff's civil rights lawsuit against media defendants in a decision filed Jan. 16, 2026.
Stephen Lynch Murray, representing himself, had appealed the Middle District of Florida's dismissal of his amended complaint alleging free speech and due process violations under 42 U.S.C. § 1983. The defendants in the case were Janelle Irwin Taylor, Peter D. Schorsch, and Extensive Enterprises Media, LLC.
According to the Eleventh Circuit's per curiam opinion in *Murray v. Taylor* (No. 25-11744), Murray argued that the district court provided inadequate notice and instructions on how to amend his complaint to avoid shotgun pleading deficiencies. He also contended the lower court failed to properly read his amended complaint.
The case stems from Murray's January 2024 filing of what the appeals court described as a "sprawling complaint, spanning 258 pages and roughly 800 paragraphs." The lawsuit appears to be based on a February 2021 article written by Taylor and published by Schorsch on a politics website operated by Extensive Enterprises Media.
The article in question discussed Murray's arrest for alleged cyberstalking, according to the court documents. Murray's civil rights claims under Section 1983 centered on allegations that the publication of this article violated his constitutional rights to free speech and due process.
Section 1983 of the federal civil rights code allows individuals to sue state and local government officials and others acting under color of state law for violations of constitutional rights. However, the statute typically requires that defendants be acting under government authority, which presents challenges for claims against private media entities.
Murray proceeded pro se throughout the litigation, meaning he represented himself without an attorney. Pro se litigants face particular challenges in federal court, as they must navigate complex procedural rules and legal standards without legal training.
The district court initially dismissed Murray's original complaint, apparently finding deficiencies in the pleading. Courts often dismiss complaints that constitute "shotgun pleadings" - complaints that fail to provide clear, concise statements of claims and instead present rambling, confusing allegations that make it difficult for defendants to respond.
After the initial dismissal, Murray filed an amended complaint attempting to cure the deficiencies identified by the district court. However, the district court ultimately dismissed the amended complaint with prejudice, meaning Murray cannot file another version of the same claims.
On appeal, Murray challenged both the procedural handling of his case and the substantive dismissal. He argued the district court should have provided better guidance on how to fix the shotgun pleading problems in his original complaint. He also maintained that the district court misread or misunderstood his amended complaint.
The Eleventh Circuit panel, consisting of Circuit Judges William H. Pryor Jr., Robin S. Rosenbaum, and Nancy G. Abudu, reviewed Murray's arguments and found them unpersuasive. In their brief per curiam opinion, the judges wrote that after "careful review," they affirmed the district court's dismissal.
Per curiam opinions are issued by the court as a whole rather than authored by a single judge, and they typically indicate the court viewed the legal issues as relatively straightforward or well-settled. The designation "NOT FOR PUBLICATION" suggests the court did not consider the decision to establish new precedent or address novel legal questions.
The case was decided on the court's "Non-Argument Calendar," meaning the judges reviewed the written briefs and record without holding oral arguments. This is common for appeals the court considers routine or where the legal issues are clear from the written submissions.
For Murray, the affirmance represents the end of his federal civil rights claims against the media defendants, at least in this litigation. Dismissals with prejudice generally prevent plaintiffs from refiling the same claims, though in some limited circumstances, appellate courts may provide opportunities to amend.
The decision reflects the challenges pro se litigants face in federal court, particularly when bringing civil rights claims against private parties. Courts maintain strict pleading standards, and plaintiffs must clearly articulate how defendants' actions violated specific constitutional rights under circumstances that trigger Section 1983 liability.
The case also illustrates the intersection between media coverage and civil rights law. While the First Amendment generally protects news reporting about public matters like arrests and criminal charges, plaintiffs sometimes attempt to use federal civil rights statutes to challenge coverage they view as harmful or inaccurate.
Murray's case was docketed as No. 6:24-cv-00006-CEM-LHP in the Middle District of Florida before reaching the Eleventh Circuit as No. 25-11744. The appeals court's decision brings the federal litigation to a close, though the underlying factual disputes between Murray and the media defendants remain unresolved through this particular legal avenue.