Riddle v. X Corp

Case: 25-50951 Document: 114-1 Page: 1 Date Filed: 07/13/2026

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit

No. 25-50951 FILED July 13, 2026 Summary Calendar ____________ Lyle W. Cayce Clerk Justin Riddle, Plaintiff—Appellant, versus X Corp., formerly known as Twitter, Incorporated, Defendant—Appellee. ______________________________ Appeal from the United States District Court for the Western District of Texas USDC No. 1:25-CV-73 ______________________________ Before Richman, Southwick, and Willett, Circuit Judges.

Per Curiam: * Justin Riddle sued X Corp. (formerly Twitter, Inc.) after X users allegedly posted his copyrighted material on the platform. The district court dismissed the case in two steps. First, it granted X Corp.’s motion to dismiss all but Riddle’s contributory-copyright-infringement claim. That same day, the court warned Riddle in a Case Management Order that continued Case: 25-50951 Document: 114-1 Page: 2 Date Filed: 07/13/2026

No. 25-50951

“inappropriate conduct in this case”—including ex parte communications, local-rule violations, and threatening or harassing language directed at opposing counsel and the court—could result in sanctions, including dismissal with prejudice. When Riddle persisted, the court dismissed the remaining claim with prejudice. See Griggs v. S.G.E. Mgmt., L.L.C., 905 F.3d 835, 844 (5th Cir. 2018) (“Rule 41(b) authorizes the district court to dismiss an action sua sponte for failure to prosecute or comply with a court order.”).

We construe pro se briefs liberally. Haines v. Kerner, 404 U.S. 519, 520–21 (1972) (per curiam). But that solicitude does not excuse a pro se appellant from meaningfully briefing his arguments. Yohey v. Collins, 985 F.2d 222, 224–25 (5th Cir. 1993). Riddle raises many objections, but he does not grapple with the district court’s reasons for dismissing the claims resolved in the Rule 12 order. 1 Those challenges are therefore abandoned. See Brinkmann v. Dallas Cnty. Deputy Sheriff Abner, 813 F.2d 744, 748 (5th Cir. 1987).

Nor does Riddle meaningfully challenge the Rule 41(b) dismissal of his remaining contributory-copyright claim. 2 He does not dispute the district Case: 25-50951 Document: 114-1 Page: 3 Date Filed: 07/13/2026

No. 25-50951 court’s account of his conduct, its warning, its conclusion that lesser sanctions would not suffice, or its finding that aggravating factors were present. He has abandoned that challenge as well. See id. Abandonment alone resolves this appeal. In any event, the district court did not abuse its discretion by dismissing Riddle’s remaining claim with prejudice. Because dismissal with prejudice is a severe sanction, it is appropriate “only when there is ‘a showing of (a) a clear record of delay or contumacious conduct by the plaintiff, and (b) where lesser sanctions would not serve the best interests of justice.’” Griggs, 905 F.3d at 844 (quoting Gates v. Strain, 885 F.3d 874, 883 (5th Cir. 2018)). “In most cases, a plain record of delay or contumacious conduct is found if one of the three aggravating factors is also present: (1) delay caused by the plaintiff; (2) actual prejudice to the defendant; or (3) delay as a result of intentional conduct.”

Griggs, 905 F.3d at 844 (quoting Stearman v. Comm’r of Internal Revenue, 436 F.3d 533, 535 (5th Cir. 2006) (per curiam)).

The district court satisfied that demanding standard. Its dismissal order identified repeated instances of contumacious conduct, explained why “lesser sanctions will not serve the interests of justice or deter [Riddle’s] disobedient, stubborn conduct,” and found all three aggravating factors present. The record supports those findings, and we see no abuse of discretion. * * * The district court’s judgment is AFFIRMED. All pending motions are DENIED.