Alecia Y. Farley v. Bank of America, N.a.

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 25-1171
ALECIA Y. FARLEY,
Plaintiff - Appellant,
and
MARVIN A. FARLEY,
Plaintiff,
v.
BANK OF AMERICA, N.A.; BANK OF AMERICA, N.A., as Successor by Merger to
BAC Home Loans Servicing, L.P.,
Defendants - Appellees.
Appeal from the United States District Court for the Eastern District of Virginia, at Richmond.
John A. Gibney, Jr., Senior District Judge. (3:14-cv-00568-JRS)
Submitted: May 22, 2025 Decided: May 28, 2025
Before KING, AGEE, and WYNN, Circuit Judges.
Affirmed by unpublished per curiam opinion.

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Alecia Y. Farley, Appellant Pro Se. Matthew Allen Fitzgerald, MCGUIREWOODS, LLP,
Richmond, Virginia, for Appellees.
Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:
Alecia Y. Farley appeals the district court’s order denying her request to amend a
prefiling injunction. We have reviewed the record and find no abuse of discretion in the
district court’s denial of leave to amend. See Cromer v. Kraft Foods N. Am., Inc., 390 F.3d
812, 817 (4th Cir. 2004) (providing standard of review). Accordingly, although we grant
Farley’s motion to supplement her informal brief, we affirm the district court’s order.
Farley v. Bank of Am., N.A., No. 3:14-cv-00568-JRS (E.D. Va. Feb. 10, 2025).
We note, however, that construing the prefiling injunction to apply to every case
Farley seeks to file in the Eastern District of Virginia is inconsistent with the requirement
that a prefiling injunction be “narrowly tailored to fit the specific circumstances at issue.”
Cromer, 390 F.3d at 818. When the filings giving rise to a prefiling injunction all relate to
a particular controversy, “[a] narrowly tailored injunction . . . would address only filings
in that or related actions. Prohibiting [the litigant] from making any filings in any unrelated
suit [would] not address the problem at issue, and [would] therefore [be] an overbroad
restriction.” Id. at 819; see also Adkins v. Whole Foods Mkt. Grp., Inc., 795 F. App’x 217,
218 (4th Cir. 2020) (vacating as overbroad an injunction prohibiting suit against “any other
defendant” without assistance of counsel or leave of court).
The order imposing the prefiling injunction notes that “[t]he Farleys have filed
several lawsuits related to the foreclosure of [their] home,” and then imposes conditions
that the Farleys must meet “[b]efore filing any such lawsuit.” Mem. Op., Farley v. Bank of
America, N.A., No. 3:14-cv-568 (E.D. Va. June 11, 2015), ECF No. 53 at 12–13. The

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injunction was affirmed on appeal, see Farley v. Bank of America, No. 15-1733 (4th Cir.
Sept. 11, 2015), and we do not disturb it here. However, consistent with our case law and
with the order imposing the injunction, we interpret the phrase “any such lawsuit” to mean
“lawsuits related to the foreclosure of the [Farleys’] home.” Id. at 12.
We dispense with oral argument because the facts and legal contentions are
adequately presented in the materials before this court and argument would not aid the
decisional process.
AFFIRMED

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