Limits on repeat lawsuits

1. Whether a federal court imposing a pre-filing injunction — a prior restraint that bears a heavy presumption against constitutional validity — is constitutionally required to find that each predicate prior filing was individually frivolous or harassing, as the Ninth and Fourth Circuits hold, or whether a court may impose an indefinite prior restraint on the First Amendment right to petition based on the aggregate volume of § 1915 dismissals without individualized frivolousness findings, without a separate evidentiary hearing, and without examining whether the predicate dismissals were entered for frivolousness or for failure to state a claim. 2. Whether, following Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), the Electronic Funds Transfer Act's definition of 'consumer' as 'a natural person,' 15 U.S.C. § 1693a(6), encompasses all natural persons regardless of their business associations, without the 'household purposes' limitation that appears nowhere in the statute and only in Regulation E — an agency gloss no longer entitled to deference — and whether dismissal without leave to amend was proper where the court acknowledged the threshold coverage question remained unresolved, and where resolving consumer standing in Petitioner's favor would establish that the notice pleading deficiency is curable by amendment, making the consumer standing question outcome-determinative of whether the amendment denial was an abuse of discretion under Foman v. Davis, 371 U.S. 178 (1962).