The Case That Keeps Going: How a Federal Judge’s Repeated Invitations Transformed a Stalker’s Grievance Into a Statewide Constitutional Threat

The documented judicial conduct pattern in this case has five components, all sourced to the federal docket.

First: Both the Third Amended Complaint and the Fourth Amended Complaint were filed at Leitman’s sua sponte suggestion. ECF No. 186 states this explicitly: “the Third Amended Complaint, was at the sua sponte suggestion of the Court” and the Fourth was similarly invited. This is not standard case management. Inviting a plaintiff to amend a complaint is an affirmative judicial act. Leitman invited it twice.

Second: In June 2024, ECF No. 147, Leitman denied defendants’ motion for summary judgment, distinguishing the Sixth Circuit’s own prior ruling in Lindke v. Tomlinson, which had held that Sheriff King could not be sued under Ex Parte Young for entering PPO information into LEIN. Leitman found that King and Kays possessed “some connection with enforcement” of the PPO statute and that LEIN entry “materially expands” enforcement circumstances, keeping the case alive against directly on-point appellate precedent.

Third: Leitman denied mootness based on Lindke’s affidavit stating he “remains concerned” about the petitioner and her family and “desires to continue to publicly comment about their actions.” At the time Leitman invited the Fourth Amended Complaint, the court had before it, in defense filings, documentation that Lindke had been a fugitive from Michigan justice, allegedly residing outside the state for approximately two years, was carrying multiple outstanding bench warrants, had been actively doxxing Hines’s home address, had made drunk threatening calls to Hines and admitted it on social media, and was openly defying court orders without consequence. The mootness basis — Lindke’s own stated desire to continue the conduct — is rendered circular by the documented conduct: Lindke was not chilling his speech because of PPO risk. He was violating PPOs continuously while a fugitive and claiming fear of PPO enforcement prevented him from speaking. He has since turned himself in and is currently incarcerated in St. Clair County on contempt. The federal case is still open.

Fourth: The Fourth Amended Complaint falsely alleged Lindke was a St. Clair County resident. ECF No. 186, filed November 10, 2025, documents that Ellison’s own representations to the court confirm Lindke’s fugitive status at the time of filing, with defense counsel characterizing him as allegedly residing outside Michigan. The false residency allegation is in the federal record before Leitman. Lindke has since surrendered to Michigan jurisdiction and is currently incarcerated in St. Clair County. No corrective order on the residency misrepresentation appears in the public docket.

Fifth: Ellison characterized the Hines PPO to Leitman as a PPO issued “solely premised on speech” on Facebook. ECF No. 186 documents this was false, with exhibits. The PPO’s social media restriction line is blank. Judge Tomlinson denied show cause motions based on social media content precisely because the PPO did not restrict speech. Ellison’s representation to Leitman was contradicted by the Hines PPO’s own text and by the pattern of Tomlinson’s rulings, both of which were before Leitman in ECF No. 186 when he allowed the Fourth Amended Complaint.

The Good Faith Question

The Judicial Conduct and Disability Act, and the broader standards governing federal case management, contemplate that courts will assess whether litigation before them is being conducted in good faith. That assessment is not optional. It is embedded in the court’s inherent authority to manage its docket, sanction misconduct, and prevent the abuse of its processes. A court that has abdicated that assessment across six and a half years of documented misconduct by a plaintiff is not managing a difficult case. It is enabling one.

Judge Leitman has before him, in his own docket, the following documented facts. The plaintiff spent approximately two years as a fugitive from Michigan justice while actively litigating in his court. The plaintiff’s counsel filed a complaint on behalf of a fugitive falsely alleging that fugitive was a Michigan resident — a misrepresentation called out in sworn defense filings before this court. The plaintiff’s counsel characterized the Hines PPO as issued “solely premised on speech” when the PPO’s social media restriction line was blank and the presiding state court judge had denied speech-based enforcement motions — also documented in sworn defense filings before this court. The plaintiff continued harassing Hines, doxxing his home address, and violating court orders while the Fourth Amended Complaint was pending — documented in sworn defense filings before this court. The plaintiff’s counsel has submitted a witness to a related proceeding who has no verifiable existence in any public record. The plaintiff’s counsel misrepresented the status of an active attorney disciplinary complaint to the Saginaw court in sworn filings.

None of this is hidden. None of it requires investigative work to surface. All of it arrived in this court through sworn filings from the defendant’s own counsel — the attorney MMRMA pays to defend the public officials Ellison is suing. Shoudy did not bury these facts in footnotes. He led with them. He organized his November 2025 brief around them. He asked Leitman to deny the Fourth Amended Complaint on the basis of bad faith, false pleadings, and futility. He documented the fugitive status. He documented the false residency allegation. He documented the mischaracterized recurrence evidence. He called the proposed amendment “presented in bad faith” in the brief’s own argument header. ECF No. 186, PageID.5744.

Judge Leitman allowed the Fourth Amended Complaint to proceed.

Understanding why requires understanding who he is. This is a man who grew up in Bloomfield Hills, practiced in the Oakland County legal corridor for twenty years, organized Harvard Law alumni gatherings with sitting federal judges, and publicly stated in 2012 that joining those judges on the federal bench was his ultimate professional dream. He got the appointment two years later. His criminal defense career was built around keeping constitutional questions alive across long timelines — he spent seventeen years on a single case without allowing procedural dismissal and described the intellectual variety of his practice as what kept things “fresh and challenging.” In that same profile, he described his primary identity outside the law as a parent. A full-time taxi driver for his kids, he said.

None of that is a character flaw in isolation. But it is a portrait of a man whose entire frame of reference — professional, social, geographic, intellectual — is insulated from the material reality of what this litigation is doing to the people it is running over. The constitutional question is genuinely interesting to him. The procedural architecture of keeping a complex First Amendment challenge alive across six and a half years is the kind of work he built his career to do. The people the constitutional question is grinding up are not abstract to the record. They are in the docket. They are just not in the frame.

That is not corruption. It is something the legal establishment produces reliably and rewards consistently: a class of legal actors whose professional formation, social world, and institutional position insulate them from the human cost of the decisions they make. The harm being caused in St. Clair County, in Macomb County, in Richland, Michigan — to women, to children, to people who used the court system the way it was designed to be used and found themselves instrumentalized by someone else’s federal constitutional strategy — does not arrive in Judge Leitman’s courtroom in any form that his training, his career, or his professional community has equipped him to weigh against the intellectual interest of the question on his docket. The record does not require him to weigh it. So he does not.

I want to be direct about what that looks like from where I am standing.

To the attorneys on both sides of this case, this is a billing matter. Ellison is paid to advance it. Shoudy is paid to defend against it. Their professional obligation is to their clients and their invoices, not to the people caught in the machinery between them. To Judge Leitman, this is an intellectually interesting constitutional question — the kind of case that keeps things “fresh and challenging,” to use his own words. It is, by every indication the record provides, something he finds professionally engaging.

It is not engaging from where I sit. It is not a constitutional experiment. It is not a billing cycle. It is not fresh or challenging.

It is wondering whether someone is going to be sent to your home. It is checking whether the process server coming to your door at night was legally authorized to be there, and discovering it was not, and watching nothing happen. It is watching a man who was convicted of distributing intimate images of his daughter’s mother without consent, who registered a domain in your daughter’s name, who harassed your children to the point where you filed a federal child safety referral, have his alleged right to comment publicly about his harassment targets treated as a weightier constitutional interest than your right to be left alone. It is watching a federal judge — a man who described his primary identity as a parent — read a docket full of that conduct and find in it only further reason to allow amendment.

Every attorney in this case knows what is happening. Every court with a record in this network knows what is happening. The judge managing the federal case that depends on all of it knows what is happening. The knowing has not changed anything. That is the part that does not appear in the constitutional analysis, in the billing statements, or in the judicial conduct orders. It is the part that appears in the lives of the people this network has targeted. We are the ones living it. We are the ones it is not fun for. We are the only ones in this entire architecture who did not choose to be here.

Why the First Amendment Argument Fails the Victims

The First Amendment does not protect harassment. It does not protect threats. It does not protect the distribution of intimate images without consent. It does not protect contacting someone who has a valid court order against you. It does not protect posting someone’s home address on social media after obtaining a PPO against you for threatening conduct. None of what Kevin Lindke has done to his victims is protected speech.

What the constitutional challenge actually asks is something narrower and more insidious: it asks a federal court to declare that Michigan’s procedure for issuing non-domestic PPOs is structurally flawed in a way that could void any PPO issued under it, including those already in existence. If the statute is declared unconstitutional as construed, the question of what happens to existing PPOs becomes live. In a case where Lindke’s documented history includes eleven-plus PPO violations in one proceeding, active violation of a Macomb County PPO while evading Michigan jurisdiction as a fugitive, and contempt committed during his own arraignment on PPO violation charges, that outcome matters to every person who has ever used Michigan’s non-domestic PPO statute to protect themselves.

The constitutional framing presents this as a free speech case. The factual record presents it as a harassment case that has been laundered through constitutional doctrine. The people bearing the cost of that laundering are the ones who filed the PPOs in the first place. They used the legal system the way it was designed to be used. They got orders. Those orders became Ellison’s exhibits. They received nothing.

The Constitutional Rights That Don’t Appear in Leitman’s Docket

Lindke v. King has consumed six and a half years of federal judicial resources on the constitutional rights of one person. The First Amendment interests of Kevin Lindke — his asserted right to comment publicly about the people he has stalked, threatened, and harassed — have been analyzed, argued, briefed sixteen-plus times, and twice invited to amendment by the presiding judge. Those interests have received the full attention of a federal court.

The constitutional rights of the people on the other side of this record have received none.

The Due Process Clause of the Fourteenth Amendment guarantees that no state shall deprive any person of liberty without due process of law. A Michigan circuit court issued each personal protection order in this case following a judicial determination that the petitioner was entitled to legal protection. Those orders are state-conferred liberty interests. If Ellison prevails, the procedural framework under which those orders were issued is declared unconstitutional — and the legal protection that a court determined each of these individuals deserved is potentially extinguished. The non-party petitioners have no standing in Lindke v. King to assert those interests. They are in the docket only as exhibits. Their Fourteenth Amendment interests do not appear in any order Leitman has issued.

The First Amendment also protects the right to petition courts for redress of grievances. Every person who obtained a PPO in this network exercised that right. What the litigation architecture has done is take those petitions and convert them, without consent and without standing to object, into federal evidence supporting the constitutional challenge of the person the petitions were filed against. The mechanism functions to penalize the exercise of the right to petition. A person who files a protection order to stop being harassed does not agree to have that order become her harasser’s federal exhibit. A court that manages this conversion for six and a half years without examining its constitutional implications for the petitioners has left a significant dimension of this case entirely unaddressed.

I am writing this as one of those petitioners. My personal protection order against Kevin Lindke is part of the evidentiary record of a federal case I have no standing to appear in. My Fourteenth Amendment interest in the protection a Michigan court determined I was entitled to receive is not a consideration that appears anywhere in the management of that case. My First Amendment right to petition the courts — which I exercised, which produced an order, which Lindke’s attorney then filed as a federal exhibit — has been converted into ammunition against the very statute my protection depends on.

My children’s situation is more direct. Lindke’s network registered a domain in my daughter’s name. His network targeted my family. I filed a federal child safety referral — NCMEC CyberTip No. 222110727, November 18, 2025 — that was referred to the Michigan State Police ICAC Task Force. There has been no documented enforcement response. My children’s safety is not a constitutional question pending before the Eastern District of Michigan. But the harassment of my children was generated by the same network whose conduct sustains the federal case that is. Judge Leitman has the documentation in his docket. It has not changed anything.

This Is Also What Misogyny Looks Like in a Courtroom

Look at who is in this record. The primary domestic PPO petitioner is a woman. Tina Troy is a woman. Dino Hines is a man, and his harassment is documented and real — but the network’s primary targets, across its entire documented history, are women. Rita Williams is a woman. Her daughter’s name was registered as a domain. Her children were targeted. The false PPO petitions filed against her in Macomb County were filed by a woman acting on behalf of a man who had already been convicted of distributing intimate images of his daughter’s mother without consent. The harassment network that coordinated the targeting of Williams was administered by a man who had been convicted of revenge porn, who physically assaulted his own mother, and who met his current girlfriend at an anti-sexual predator rally — a detail the record confirms without any need for editorial comment.

This is not incidental. Gendered harassment — stalking, revenge porn, domain registration in a victim’s name, nighttime residential approaches, the weaponization of family court proceedings, the targeting of children — follows documented patterns that researchers, federal agencies, and the United Nations have identified as forms of technology-facilitated violence disproportionately directed at women. The conduct in this record matches those patterns with precision. The network’s tools are the tools of gendered harassment: intimate image abuse, doxxing, identity impersonation, coordinated reputational attack, and the exploitation of legal proceedings as instruments of control.

None of that appears in Leitman’s case management. The word “women” does not appear in the constitutional analysis of a case whose entire evidentiary predicate was built on the targeting of women. The gendered pattern of the underlying conduct — the documented history of a man who distributed intimate images of his daughter’s mother, registered domains in women’s and children’s names, sent a process server to a woman’s home at night in a procedurally void filing, and coordinated a harassment network that targeted female journalists, advocates, and private individuals — has not been examined in a single order the court has issued across six and a half years.

Federal courts are not required to analyze the sociological dimensions of every civil rights case before them. But a court managing a constitutional challenge that has survived six and a half years specifically because it continuously generates new PPOs — and those PPOs are obtained by women who have been stalked, threatened, doxxed, and harassed by the same man across the same documented pattern — has before it a record that is not gender-neutral. Treating it as gender-neutral is itself a choice. It is a choice this court has made, consistently, across every order it has issued, in a case whose foundational conduct the court’s own docket documents as systematically directed at women.

The Three-Track State Failure

The state is not a passive bystander in this pattern. The Michigan Attorney General’s Office is actively present in three distinct roles across the network, each of which functions at cross-purposes with victim protection.

Deputy Solicitor General B. Eric Restuccia defends the state’s interest in the non-domestic PPO statute in Lindke v. King. If he succeeds, the constitutional challenge fails and the statute survives. If Ellison succeeds, the statute falls and every victim PPO is potentially void. The state’s defense of the statute is therefore directly in the interest of the victims. But the state’s two other roles in this network cut against them.

A second documented role involves the AG’s Office’s handling of Williams’s situation more directly. Williams presented exculpatory evidence contesting the factual basis of the Murray PPO petitions filed against her in Macomb County proceedings, including pay stubs and a service form. That exculpatory evidence was before the AG’s Office. The office pursued incarceration of Williams regardless. One AG attorney was therefore simultaneously defending the statute that protects Lindke’s victims in federal court while another arm of the same office pursued action against one of those victims on petitions Williams had documented as false. The contradiction is institutional, not personal, but it is in the record.

AAG Tyler Kitzmiller represents Colonel James F. Grady II, the Director of the Michigan State Police. The Michigan State Police administers the Internet Crimes Against Children Task Force. The NCMEC CyberTip filed by Williams on November 18, 2025, regarding Lindke’s harassment of her minor children, was referred to that task force. No enforcement response has been documented. Kitzmiller’s client runs the agency. The referral went there. The connection is institutional, not personal, but the outcome is the same: no action.

These roles are not coordinated. They are structural. The AG’s Office has obligations to the state, to its clients, and to its institutional role. Those obligations, pursued independently, produce a pattern where the same agency defends the legal tool victims rely on, pursues action against one of those victims in related proceedings, and represents the enforcement body that did not respond to a federal child safety referral about their harasser. No individual attorney in the AG’s Office is responsible for all three tracks. The institution produces the pattern through normal operations.

The Question the Case Does Not Ask

Lindke v. King, as framed by Ellison, asks whether Michigan’s non-domestic PPO statute is constitutionally applied when it restricts allegedly defamatory online speech without a prior adversarial hearing. That is the question on the docket.

The question not on the docket is simpler: what does the constitutional framework owe the people who have been subjected to years of documented harassment, who used the legal system to protect themselves, and whose legal protection has become the evidentiary foundation for a challenge that could void it?

The answer, under the current architecture of this case, is nothing. They are not plaintiffs. They are not intervenors. They are not represented. They appear in the federal record as the sources of the PPOs that Ellison converts into constitutional violations. Their harm is the raw material of the litigation. Their continued exposure to that harm while the litigation proceeds is not a consideration that appears in any order Leitman has issued.

That is not a procedural accident. It is a structural feature of how this case has been built and allowed to grow. A constitutional challenge to a protective statute, brought by a person who has been violating that statute’s orders continuously, managed by a federal judge who has twice invited amendment and once denied summary judgment against circuit precedent, produces a framework in which the people the statute was designed to protect become the instrument of its undoing.

The case keeps going. The victims keep paying. The meter runs.

Everyone Knows. Nothing Changes.

This is not a situation where the harm is hidden or where the relevant actors lack information. The harm is documented. The actors have the documentation. None of it has changed anything.

Todd J. Shoudy has been defending King and Kays in this case for six and a half years. He has filed over sixteen briefs. His November 10, 2025 filing — ECF No. 186 — is the most comprehensive single-document account of Lindke’s conduct in the federal record. Shoudy documented the fugitive status. He documented the doxxing of Hines’s home address. He documented the drunk phone calls and the social media admissions. He documented the false residency allegation. He documented Ellison’s mischaracterization of the Hines PPO to the court. He put every piece of it in a sworn federal filing and handed it to Leitman. Shoudy knows exactly what is happening to the people on the other side of this network. His firm’s institutional interest — defending MMRMA-covered public entities against a plaintiff who manufactures the evidence that sustains his own case — aligns with documenting that harm. He has documented it. The case continues.

Philip Ellison has been a member of the Through My Eyes Facebook group since July 6, 2020. He has watched his client’s harassment network operate for years. He has filed four amended complaints that depend on the PPOs generated by that harassment. He filed Dino Hines’s PPO as a federal exhibit while Lindke was simultaneously violating it, doxxing Hines’s address, and making threatening calls. He submitted a phantom witness to the Saginaw court. He misrepresented the AGC complaint status. He knows what this network has done to the people in this record. He has built his constitutional case on top of it.

Six counties have documentation of the harm. St. Clair County has seven confirmed Ellison matters and a decade of PPO proceedings in its court record. Macomb County has the PPO proceedings, the contempt, the false petitions, and the retaliatory filings in its record. Saginaw County has the lawsuit and the Omnibus Motion documenting the harassment network as the plaintiff’s witness list. Barry County has its own documented institutional record. Sanilac County has the Dinoto suit. The Eastern District of Michigan federal court has sixteen-plus defense briefs, four amended complaints, two bench warrants, a documented fugitive, a phantom witness, false pleadings, and a NCMEC child safety referral in its connected record. Every one of these venues has information establishing the harm. Not one of them has produced a result that stops it.

What the Law Does Not Yet Require

This case is not an anomaly. It is a demonstration of what the current legal architecture permits when litigation is designed not to resolve a dispute but to sustain one. The record in Lindke v. King identifies at least three structural gaps that no existing federal or state mechanism adequately addresses. The people harmed by those gaps are not corporations, not government entities, and not well-resourced institutional litigants. They are private individuals who used the courts the way they were designed to be used, and found themselves instrumentalized by someone else’s federal constitutional strategy.

The Non-Party Victim Gap

There is no federal procedural mechanism by which a private individual whose personal protection order has been filed as evidence in a constitutional challenge can intervene, object, or seek compensation in that proceeding. Tina Troy was a named defendant and could move for dismissal. The remaining victims are not in the case at all. They are present only as the sources of the documents Ellison files. They have no standing to challenge how those documents are characterized to the court, no right to be heard on the question of whether the conduct that generated their PPOs was constitutionally protected speech or documented harassment, and no remedy when the characterization used in the federal record bears no relationship to the factual record of the underlying proceedings.

This gap is not incidental. It is structural. Federal civil rights litigation under 42 U.S.C. § 1983 is designed to protect individuals from unconstitutional state action. It was not designed to provide a mechanism by which a documented harasser can convert his victims’ protection orders into constitutional evidence while those victims have no procedural standing to contest that conversion. Reform that creates a limited intervention right for non-party individuals whose court-issued protective orders are used as recurrence evidence in federal constitutional challenges would directly address what this case has exposed.

The Cost Displacement Gap

No one who absorbed the human cost of this litigation has been compensated for it. The defense costs flow to MMRMA’s liability reserves and are distributed across the pool membership. The state’s litigation costs flow to the AG’s budget. The professional costs of this litigation — the hours Tina Troy spent as a foundational petitioner in a federal case she never sought, the proceedings a primary domestic petitioner navigated while her protection orders became class action predicates, the violation reports Dino Hines filed while Lindke violated his PPO from outside Michigan’s jurisdiction — those costs have no mechanism for recovery.

Fee-shifting statutes in constitutional litigation exist to incentivize the vindication of constitutional rights. They were not designed to transfer wealth from public entities to attorneys who manufacture the evidentiary conditions their cases require. When a plaintiff’s conduct generates the state action that sustains a constitutional challenge, and that conduct produces documented harm to private individuals who have no voice in the litigation and no path to compensation, the fee-shifting framework is operating exactly backward from its intended purpose. Reform that creates a cost-recovery mechanism for non-party individuals demonstrably harmed by litigation-sustaining harassment would begin to correct that inversion.

The Manufactured Controversy Gap

Federal courts are courts of limited jurisdiction. The case or controversy requirement exists precisely to prevent federal courts from becoming vehicles for abstract constitutional debate untethered from genuine, ongoing harm. The mootness doctrine is one of the mechanisms by which that requirement is enforced. In Lindke v. King, the mootness doctrine has been defeated by a plaintiff whose conduct continuously generates the recurrence evidence his case requires to survive.

No existing judicial standard requires a federal court to examine whether the conduct underlying recurrence evidence was itself the calculated product of a litigation strategy rather than a genuine instance of ongoing constitutional injury. Leitman accepted Ellison’s characterization of each new PPO as evidence of ongoing unconstitutional enforcement without examining the conduct that generated those PPOs — conduct that defense counsel documented, in sworn filings before him, as threatening, harassing, and in direct violation of existing court orders. A judicial standard that requires examination of whether recurrence evidence reflects genuine constitutional injury or manufactured litigation predicate would not eliminate constitutional challenges. It would require them to be built on honest foundations.