U.S. Court of Appeals for the Fifth Circuit, 2026

Rodriguez v. Meta Platforms

U.S. Court of Appeals for the Fifth Circuit · Decided August 25, 2026

Opinion

Case: 26-30228 Document: 58-1 Page: 1 Date Filed: 08/25/2026

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

No. 26-30228 FILED August 25, 2026 Summary Calendar ____________ Lyle W. Cayce Clerk Hiran Rodriguez, Plaintiff—Appellant, versus Meta Platforms, Incorporated; Apple, Incorporated; T- Mobile USA, Incorporated; AT&T Enterprises, L.L.C.; X Corporation, a Nevada Corporation, agent of Twitter, Incorporated; Kansas City Southern Railway Company; LCMC Healthcare Partners, L.L.C.; Third District Volunteer Fire Department; Gray Local Media, Incorporated; Associated Press; Jefferson Parish; Jefferson Parish Sheriff’s Office; Joseph P. Lopinto, III, Sheriff; Andres Fuentes; Gloria Pazmino; Susanne Rust; Ryan McCafferty; Paul MacInnes; Jonathan Liew; James Ochoa; Demicia Inman; Jamie Spangher; Maya Gebeily; Versha Sharma; Elon Musk, Chief Executive Officer X Corporation; Mark Elliot Zuckerberg, Chief Executive Officer Meta Platforms, Incorporated; Unidentified Parties; Haleluya Hadero, Defendants—Appellees. ______________________________ Appeal from the United States District Court for the Eastern District of Louisiana USDC No. 2:25-CV-197 ______________________________ Case: 26-30228 Document: 58-1 Page: 2 Date Filed: 08/25/2026

Before Davis, Richman, and Oldham, Circuit Judges.

Per Curiam: * Pro se Plaintiff-Appellant Hiran Rodriguez sued 27 Defendants, including companies, journalists, and local government entities. He broadly alleged Defendants surveilled his electronic communications and defamed him. But he provided no further factual basis for his suit.

Several Defendants moved to dismiss. Rodriguez filed multiple motions in response. Among these was a request for sanctions in which Rodriguez contended that Defendants obstructed justice by seeking to dismiss his suit. The district court denied Rodriguez’s motion and admonished him for the frivolous filing. Rodriguez then filed a motion for recusal, contending that the district judge was biased. The court denied the motion, explaining that adverse rulings are not grounds for recusal.

The district court then addressed the pending motions to dismiss.

Acting on the report and recommendation of a magistrate judge, the court explained that Rodriguez’s complaint failed to meet federal pleading standards. Given Rodriguez’s pro se status, it afforded him 14 days to amend.

But considering Rodriguez’s history of abusive filings, it directed Rodriguez to file nothing further until after he submitted the amended complaint.

Rodriguez responded with more than 20 filings over the ensuing 14 days. Among these was a renewed motion to recuse the district judge. But Rodrguez failed to file an amended complaint. Accordingly, the district court Case: 26-30228 Document: 58-1 Page: 3 Date Filed: 08/25/2026

No. 26-30228 dismissed the suit. Rodriguez appealed, and a panel of this court later affirmed the dismissal. 1 While his appeal was pending, Rodriguez filed a Rule 60(b) motion in the district court. He argued the court violated his constitutional rights by prohibiting him from filing motions until he submitted the amended complaint and by failing to address his second recusal motion prior to dismissal. The district court denied Rodriguez’s motion, and he timely noticed this appeal. Our review is for abuse of discretion. 2 Rodriguez’s appeal is meritless. Regarding the temporary filing prohibition, district courts “have the inherent power to manage their own proceedings and control the conduct of those who appear before them.” 3 Given Rodriguez’s filing history, the district court’s decision to limit his filings for a brief 14-day period pending amendment was well within reason.

Rodriguez’s argument that reversal is warranted because the district court dismissed his suit without considering his second motion to recuse is similarly unpersuasive. That motion was duplicative and baseless: as the district court had already explained, a judge’s adverse rulings against a party are not grounds for recusal. 4 Accordingly, Rodriguez has failed to demonstrate any error sufficient to obtain relief on appeal. 5

Case: 26-30228 Document: 58-1 Page: 4 Date Filed: 08/25/2026

No. 26-30228

AFFIRMED.

* This opinion is not designated for publication. See 5th Cir. R. 47.5. 1 See Rodriguez v. Meta Platforms, No. 25-30297, 2026 WL 660771 (5th Cir. Mar. 9, 2026). 2 See Williams v. Chater, 87 F.3d 702, 705 n.2 (5th Cir. 1996). 3 Rodgers v. La. Bd. of Nursing, 665 F. App’x 326, 328 (5th Cir. 2016). 4 See Liteky v. United States, 510 U.S. 540, 555 (1994) (“[J]udicial rulings alone almost never constitute a valid basis for a bias or partiality motion.”). 5 See 28 U.S.C. § 2111 (We disregard “errors or defects which do not affect the substantial rights of the parties.”).

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