The U.S. Court of Appeals for the Eleventh Circuit has affirmed the dismissal of yet another lawsuit filed by Waseem Daker, an inmate whom the court characterized as a 'serial litigant' responsible for flooding federal courts with frivolous litigation.
In the unpublished opinion filed Jan. 9, 2026, in *Waseem Daker v. Commissioner, Georgia Department of Corrections* (11th Cir. 2026), a three-judge panel consisting of Circuit Judges Jordan, Abudu, and Anderson upheld the U.S. District Court for the Middle District of Georgia's dismissal of Daker's civil rights lawsuit.
The case targeted multiple Georgia Department of Corrections officials, including Commissioner, Facilities Director Jack Koon, Deputy Facilities Director Johnny Sikes, Field Operations Director Robert Toole, and Deputy Field Operations Director Ahmad Holt, among others.
The appeals court's per curiam opinion referenced Daker's extensive litigation history, noting that he has 'clogged the federal courts with frivolous litigation by submitting over a thousand pro se filings in over a hundred actions and appeals in at least nine different federal courts.' This characterization stems from a 2019 Eleventh Circuit decision in *Daker v. Jackson*, where the court documented the prolific nature of his legal filings.
Daker's litigation pattern has prompted extraordinary judicial intervention. In April 2022, the Eleventh Circuit upheld a permanent litigation filing injunction issued by the U.S. District Court for the Northern District of Georgia. This injunction imposes stringent requirements on any new lawsuits or petitions Daker attempts to file.
Under the terms of the injunction, Daker must post a $1,500 contempt bond in addition to any required filing fees when initiating new legal proceedings. The injunction also mandates that he detail his complete litigation history in any new filing and append a copy of the filing injunction order to each submission.
These measures represent the federal judiciary's attempt to manage what courts have characterized as an abuse of the legal system. The filing injunction serves as both a financial deterrent and a procedural safeguard designed to discourage frivolous litigation while ensuring courts can efficiently process legitimate claims.
The current case, assigned docket number 24-13074 and processed on the non-argument calendar, represents the continuation of a pattern where Daker's legal challenges consistently face dismissal by both district and appellate courts. The Eleventh Circuit's decision to issue an unpublished opinion signals the court's view that the case does not present novel legal issues worthy of precedential treatment.
Daker's status as a pro se litigant means he represents himself without legal counsel, a factor that often complicates court proceedings but does not excuse frivolous filings. Federal courts maintain broad discretion to dismiss cases that fail to state valid legal claims or that appear designed to harass defendants rather than seek legitimate relief.
The case originated in the Middle District of Georgia under docket number 5:22-cv-00340-MTT-CHW, where the district court initially dismissed Daker's claims. The specific allegations against the Georgia Department of Corrections officials and the district court's reasoning for dismissal were not detailed in the available portions of the appellate opinion.
Prison conditions litigation represents a significant portion of federal civil rights cases, with inmates frequently challenging various aspects of their confinement under 42 U.S.C. § 1983, which provides a cause of action for violations of constitutional rights under color of state law. However, courts distinguish between legitimate grievances about unconstitutional conditions and frivolous complaints that lack legal merit.
The Eleventh Circuit's affirmance effectively ends this particular legal challenge, though it does not prevent Daker from filing future lawsuits, provided he complies with the terms of the filing injunction. The permanent nature of the injunction means these procedural requirements will continue to apply to any new litigation Daker initiates.
This decision reflects the ongoing tension between ensuring incarcerated individuals retain access to federal courts to challenge genuine constitutional violations while preventing the abuse of judicial resources through repetitive, meritless litigation. The filing injunction represents one tool courts use to balance these competing interests.
The case demonstrates how federal appellate courts handle repetitive litigation from prolific filers who have established patterns of unsuccessful legal challenges. By affirming the dismissal and processing the case on a non-argument calendar, the Eleventh Circuit efficiently resolved the appeal while conserving judicial resources for cases presenting more substantial legal questions.