Dwight L. Mathena, Roger Sullivan, Patrick W. Few, Jack Grimes, Jr., Kenneth Bennett, Jeffrey L. Wolfe, Kenneth…

Summary

The Supreme Court of Appeals of West Virginia reversed, in part, Randolph County circuit court orders enjoining inmate Eugene Blake from filing motions, letters, or any communications with the clerk or court unless signed by a licensed attorney, holding that a single ambiguously worded letter did not demonstrate the clear intention to obstruct the administration of justice required before denying the fundamental right of self-representation. The Court announced that before limiting a prisoner's court access, a circuit court must afford a show-cause opportunity, find a clear obstructive intent in the record, craft the order to preserve adequate, effective, and meaningful access, and include findings and conclusions adequate for appellate review. It affirmed, however, that the underlying conditions-of-confinement and medical-care habeas claims were finally dismissed when the Court refused the sole timely appeal in 2003. Justice Maynard dissented in part, contending Blake's written threat to flood the court justified the injunction, while concurring in the finality of the dismissed habeas issues.