Case: 25-137 Document: 23 Page: 1 Filed: 09/25/2025

NOTE: This order is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________ In Re BEN WILLIAMS, Petitioner ______________________ 2025-137 ______________________ On Petition for Writ of Mandamus to the United States District Court for the Western District of Louisiana in No. 3:16-cv-00777-TAD-JPM, Judge Terry A. Doughty. ______________________ ON PETITION ______________________ Before LOURIE, PROST, and CHEN, Circuit Judges.

PER CURIAM.

ORDER Ben Williams petitions for a writ of mandamus seek- ing, inter alia, to direct the United States District Court for the Western District of Louisiana to vacate its order deny- ing his motion for leave to appear pro hac vice in Luv n’ care Ltd. v. Laurain, No. 3:16-cv-777 (W.D. La.). Luv n’ care, Ltd. (“LNC”) and Nouri E. Hakim oppose the petition.

Mr. Williams replies. We deny the petition.

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I.

In 2016, LNC brought that action against Eazy-PZ, LLC (EZPZ) in the Western District of Louisiana alleging unfair competition and seeking a declaratory judgment that it did not infringe EZPZ’s design patent that had been prosecuted by Mr. Williams, then a patent agent. EZPZ counterclaimed for infringement. In February 2025, fol- lowing an eight-day bench trial during which Mr. Williams testified, the district court found EZPZ’s patent unenforce- able based in part on Mr. Williams’s inequitable conduct.

The court subsequently entered a final judgment and is- sued orders denying EZPZ’s post-judgment motions.1 In March 2025, following trial and the court’s inequita- ble conduct judgment, Mr. Williams moved to appear pro hac vice on behalf of EZPZ. On March 21, 2025, the court denied that request, citing its finding that Mr. Williams had engaged in inequitable conduct. Mr. Williams moved for reconsideration, contending that denying his motion without a hearing violated In re Evans, 524 F.2d 1004, 1008 (5th Cir. 1975). On May 22, 2025, the district court denied that motion. Mr. Williams then filed this petition seeking a writ of mandamus to, among other things, com- pel the district court to hold a hearing on his motion.

II.

A writ of mandamus requires a petitioner to show that he has a clear and indisputable right to relief, that he has no other adequate avenue for relief, and that issuance of this extraordinary relief is appropriate under the circum- stances. Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380–81 (2004). Mr. Williams has not satisfied that

1 On September 9, 2025, EZPZ notified the district court that it filed a voluntary petition for relief under Chapter 11 of the Bankruptcy Code triggering an auto- matic stay of the litigation under 11 U.S.C. § 362.

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standard here. Mr. Williams has not shown that an appeal following entry of final judgment would be an inadequate alternative to challenge the denial of the motion for leave to appear pro hac vice. Cf. Melendres v. Maricopa Cnty., 661 F. App’x 917, 918 n.1 (9th Cir. 2016) (“Ordinarily, a putative intervenor can raise the denial of a pro hac vice application in an appeal from a final judgment.”); Roma Const. Co. v. aRusso, 96 F.3d 566, 577 (1st Cir. 1996) (ad- dressing party’s challenge to denial of its counsel’s motion for admission pro hace vice on final judgment).

Nor has Mr. Williams shown a clear and indisputable right to his requested hearing. He relies exclusively on Ev- ans, where the Fifth Circuit held, in a criminal case, that the defendant’s attorney could not be denied pro hac vice admission without a hearing to address any specific allega- tions as to how he failed to satisfy the necessary profes- sional and ethical qualifications. Since Evans, the Supreme Court has held out-of-state attorneys have no con- stitutional right to such a hearing, see Leis v. Flynt, 439 U.S. 438, 442–43 (1979), and courts have understood Evans as applying to “pre-trial motions” for admission, Schlum- berger Techs., Inc. v. Wiley, 113 F.3d 1553, 1561 (11th Cir. 1997); U.S. v. Dinitz, 538 F.2d 1214, 1223 (5th Cir. 1976) (“Evans merely attempted to establish standards applica- ble to a pretrial motion to appear pro hac vice.”).

Evans did not involve the situation here: an attorney, who testified at trial about his conduct, seeking pro hac vice admission after the district court found he engaged in un- ethical behavior. And what Evans did involve—a criminal defense attorney being denied a pre-trial pro hac vice mo- tion based merely on general accusations about the attor- ney’s demeanor without a hearing to respond—is sufficiently different such that we cannot say on limited mandamus review that Mr. Williams has demonstrated a clear and indisputable right to the relief he seeks under the circumstances of this case. Mr. Williams’s other requests Case: 25-137 Document: 23 Page: 4 Filed: 09/25/2025

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are on the merits of the underlying case. Since he is not a party to those proceedings, we deny the petition in full.

Accordingly, IT IS ORDERED THAT: The petition is denied.

FOR THE COURT

September 25, 2025 Date