Court “Sanctions” SAD Scheme Judge Shopping—Crimpit v. Schedule A Defendants

Another SAD Scheme plaintiff has been caught judge-shopping. The court’s timeline:

• March 10, 2025: plaintiff files a SAD Scheme complaint in SDFla, Miami division, that is assigned to Judge Ruiz.
• March 12, 2025: plaintiff files the sealed Schedule A enumerating 102 defendants.
• April 8, 2025: Judge Ruiz issues an “omnibus order” regarding the SAD Scheme (I will have more to say about that order in a forthcoming post).
• April 15, 2025: plaintiff voluntarily dismisses the case, which Judge Ruiz granted on April 16.
• April 18, 2025: plaintiff files a new case in SDFla, Ft. Lauderdale division, assigned to Judge Dimitrouleas. The new complaint does not indicate that it is related to any other case. Nevertheless, the court says the “Complaint appears identical to the Complaint in the Judge Ruiz action that was voluntarily dismissed 2 days prior.”
• April 21, 2025: plaintiff files the sealed Schedule A, “which listed the same identical 102 Defendants as in” the Judge Ruiz case.

The opinion doesn’t indicate how Judge Dimitrouleas identified the overlap. As you can imagine, he was not pleased by the apparent judge-shopping. The lawyer tried to justify his activity based on how he interpreted Judge Ruiz’s orders, but Judge Dimitrouleas found that explanation unpersuasive. (“There is no reasonable reading of Judge Ruiz’s Omnibus Order that would allow for the interpretation set forth in his Response”).

The court summarizes:

Plaintiff’s counsel was attempting to manipulate the Court’s random assignment process in hopes of circumventing Judge Ruiz’s requirements by landing a different judge for the newly filed identical complaint….the Court finds that Plaintiff’s counsel abused Fed. R. Civ. P. 41(a)(1) to engage in judge shopping, a sanctionable offense.

Having found a “sanctionable offense,” the judge does indeed “sanction” the lawyer, but…

The court doesn’t dismiss the case with prejudice. WHAT??? The lawyer tried to pull a fast one on the judge, but the judge still permits the new case to proceed before a judge other than Judge Ruiz. Incredible. This is yet another example of how judges can be skittish about appropriately punishing obvious SAD Scheme abuses, even when they expressly identify the abuse. That tendency only encourages further misbehavior.

The judge does impose a $1k fine on the lawyer (big whoop) and requires the lawyer to notify the 102 defendants of the judge’s order (even bigger whoop given how few of them are likely to appear in court).

In other words, for the cost of $1k and some loss of the lawyer’s reputation, the lawyer achieved his judge-shopping goal. Nice.

In support of this weak-sauce response, the judge also acknowledges the lawyer’s “self-imposed sanctions” where he promises to:

• assign a case manager to track deadlines
• add a lawyer to the team to ensure all orders “are properly docketed, distributed, and understood”
• have another lawyer review each court order “to confirm that the required action is understood and that there are no questions as to what action is required.”

What? I’m sorry, but these are not sanctions. They are called “lawyering.”

The sanctioned lawyer is Leigh Salomon, a staff attorney at Boies Schiller Flexner LLP. His LinkedIn profile indicates that he got his Florida law license in 2024. His junior status partially explain the “self-sanctions” as babysitting. Then again, the fact Boies Schiller wasn’t already taking these supervisory steps raises lots of questions about the firm’s existing supervision and training.

[Note: It’s a standard trope that law school graduates are recommended to start their careers in Biglaw because those firms are supposed to offer the necessary apprenticeship/training to supplement what law school didn’t teach. However, as perhaps Salomon can attest, Biglaw training and supervision of junior attorneys is often oversold.]

Indeed, incredibly, Salomon took the fall in this case solo. Marshall Dore Louis also made an appearance in the case, but the court doesn’t mention Marshall at all in the sanctions order. Normally, rather than just benchslapping a second-year associate, judges will sanction the supervising attorney too. Marshall apparently walks away from this incident without a scratch.

I didn’t research how many SAD Scheme cases have been filed by Boies Schiller, but this isn’t their first SAD Scheme rodeo. Most notably, they are handling Pres. Trump’s recent SAD Scheme litigation. Boies Schiller describes itself as an “elite” litigation firm (literally their home page headline is “The Elite Litigation Firm”), but that positioning is discordant with bottom-feeding SAD Scheme privateering. Getting caught judge-shopping raises further questions about the firm’s eliteness. #StopTheSADScheme.

Case Citation: Crimpit Group Ltd v. Schedule A Defendants, No. 25-cv-60756-WPD (S.D. Fla. Sept. 17, 2025)