The U.S. Court of Appeals for the Third Circuit issued a non-precedential decision affirming a lower court's dismissal of a lawsuit filed by Zia Hassan Shaikh against multiple New Jersey state agencies and officials. The case, *Zia Hassan Shaikh v. State of New Jersey-Department of Banking & Insurance* (3d Cir. 2026), involved Shaikh's challenge to the revocation of his professional licenses.
Shaikh, representing himself pro se, filed the original complaint in 2019 in the U.S. District Court for the District of New Jersey. The lawsuit stemmed from the revocation of his New Jersey licenses to produce insurance and to sell real estate. His complaint targeted various state defendants involved in the revocation process.
The defendants named in the case included the State of New Jersey Department of Banking & Insurance, Division of Insurance, along with multiple officials in both their official and individual capacities. These officials included Marlene Caride, who served as Commissioner, Aurelio Romero, Executive Director of the Real Estate Commission, and Lauren Glantzberg, Supervisor of Investigations. The lawsuit also named attorney Brian M. Thorn, the law firm White, Fleischner & Fino, and Deputy Attorney General Ryan Schaffer.
The district court, presiding under the Honorable Judge Georgette Castner, ultimately dismissed Shaikh's claims. Following the dismissal, Shaikh filed a motion pursuant to Federal Rule of Civil Procedure 60(b) and (d), seeking relief from the court's judgment. Rule 60(b) allows courts to relieve parties from final judgments under certain circumstances, including mistake, newly discovered evidence, or fraud. Rule 60(d) addresses the court's power to entertain independent actions to relieve a party from a judgment.
The district court denied Shaikh's Rule 60(b) and (d) motion. When Shaikh sought reconsideration of that decision, the court again denied his request. Additionally, the district court imposed a filing injunction against Shaikh, restricting his ability to file future papers without court permission. Such injunctions are typically imposed when a litigant has filed repetitive or frivolous motions that burden the court system.
On appeal to the Third Circuit, Shaikh challenged both the denial of his Rule 60(b) and (d) motion and the court's denial of reconsideration, as well as the imposition of the filing injunction. The case was submitted to the appeals court on Dec. 19, 2025, pursuant to Third Circuit Local Appellate Rule 34.1(a), which allows for disposition without oral argument when the appeal lacks substantial merit.
A three-judge panel consisting of Circuit Judges Bibas, Chung, and Bove heard the appeal. The court issued a per curiam opinion on Jan. 22, 2026, meaning the decision was unanimous and unsigned by any individual judge. Per curiam opinions are often used for cases that are considered straightforward or that follow established precedent.
The Third Circuit affirmed all aspects of the district court's rulings. The appeals court found no error in the district court's denial of Shaikh's Rule 60(b) and (d) motion, indicating that Shaikh failed to demonstrate grounds for relief from the original judgment. The court also upheld the denial of reconsideration and the imposition of the filing injunction.
The opinion was designated as "NOT PRECEDENTIAL," meaning it cannot be cited as binding authority in future cases. Federal courts of appeals often issue non-precedential decisions for cases that apply established law to particular facts without creating new legal principles.
The case illustrates the regulatory oversight exercised by New Jersey state agencies over licensed professionals in the insurance and real estate industries. The Department of Banking & Insurance and the Real Estate Commission have authority to investigate misconduct and revoke licenses when professionals violate state regulations or ethical standards.
For practitioners in New Jersey's insurance and real estate sectors, the case serves as a reminder of the regulatory framework governing professional conduct. The state's ability to revoke licenses represents a significant enforcement tool to protect consumers and maintain industry standards.
The court's imposition of a filing injunction reflects the judiciary's authority to manage its dockets and prevent abuse of the court system through repetitive or meritless filings. Such injunctions are reserved for cases where a litigant has demonstrated a pattern of filing frivolous or harassing motions.
Shaikh's case also highlights the challenges faced by pro se litigants in federal court. Without legal representation, individuals must navigate complex procedural rules and substantive law, often resulting in unsuccessful outcomes when challenging government regulatory actions.
The Third Circuit's affirmance brings finality to the litigation, leaving Shaikh's license revocations intact. The decision reinforces the deference federal courts typically show to state regulatory agencies acting within their authority to oversee licensed professionals.