Published opinion, 22 July 2025 · source · PDF · 8 pages
Additionally, he introduced arguments outside the scope of this appeal and cited numerous false legal authorities and hallucinated cases. ¶ 3 Zajradhara routinely sent inflammatory emails to opposing counsel and judicial staff, often including several unrelated parties as recipients.
DISCUSSION A. Zajradhara’s Violations of the Supreme Court Rules ¶ 8 NMC moved this Court to sanction Zajradhara for his citations to hallucinated case law and failure to comply with Supreme Court Rules. While Zajradhara is appearing before this Court pro se, his status as an appellant does not excuse his failure to follow the rules.
Second, his brief has procedural irregularities under Rule 32, including the lack of a cover page and improper formatting. Third, and most egregious, his argument section violates Rule 28, which requires citations to “authorities and parts of the record on which the appellant relies.” Zajradhara cites three cases that either do not exist or misrepresent the content of the cited material. For example, Zajradhara cites In re Estate of Tudela , 2024 MP 9 ¶ 17 to “emphasiz[e] procedural fairness in judicial proceedings.” However, the cited paragraph discusses that self- represented litigants are not excused from following the rules.
Finally, Santos v. Santos, 2023 MP 5 ¶ 10, also cited by Zajradhara, simply does not exist. The improper citations are not limited to his brief, but reoccur throughout the duration of this appeal.
The improper citations are not limited to his brief, but reoccur throughout the duration of this appeal. In prior motions, he has cited to several nonexistent cases and legal authorities, including: “Mallory v. Norfolk Southern Ry.
Zajradhara requests leniency instead of sanctions; however, we cannot, in good faith, excuse the repeated violations after multiple warnings. Courts have imposed sanctions on pro se litigants for filings that cite nonexistent case law. See, e.g., Kruse v.
App. 2024) (dismissing pro se appellant’s case due to numerous citations to fabricated, non-existent case law and imposing a $10,000 fine for the opposing party’s legal fees). Although this Court has yet to sanction a pro se litigant, we find that such an action is appropriate.
Zajradhara’s Opening Brief, in any of its four forms, presents no cognizable legal or factual argument. Although it purports to rely on legal reasoning and authority, the cited authorities are nonexistent or provide no support for the arguments asserted. He has also failed to submit an appendix or any part of the record.