Navigating the U.S. judicial system can be challenging, even for legal professionals. Regardless of planning, research, and presentation, not every ruling is going to go the way you hope, nor will all of your filings be well-received.
For litigants without a J.D., the frustrations they encounter can lead them to adopt different approaches. Of all the possible alternatives, grabbing a pen and forging a district judge’s signature is definitely not the wisest option available.
U.S. District Court Judge Phillip Simon dismissed one of the forgery charges against Walter J. Brzowski on May 11, 2026, ruling that a $25,000 fine imposed by the Executive Committee prohibits further prosecution under the Fifth Amendment’s Double Jeopardy clause. While that’s good news for Brzowski, it doesn’t make the other 10 pending forgery charges against him magically disappear. There’s also the matter of paying the assessed fine.
Brzowski’s ill-advised plan to forge the signatures of not one but two federal court Chief Judges has him facing serious penalties. Given that the potential sanctions stem from his disruptive antics as a pro se litigant, members of the Circuit Court of Cook County, the Appellate Court for the Seventh Circuit, and the United States District Court for the Northern District of Illinois are probably hoping that Brzowski retains professional legal counsel going forward.
Signed, Sealed, Delivered (as a Felony Offense)
If nothing else, Walter Brzowski has shown a remarkable talent for holding onto a grudge. His battle with judges, clerks, and other court staff in Chicago has been raging since 2001. A quarter of a century ago, Brzowski’s wife initiated divorce proceedings against him in Illinois state court. The marriage was dissolved, with custody of their children awarded to his now ex-wife. Judging by the nine lawsuits brought in federal court between 2003 and 2007, he was not pleased with the ruling. All were filed pro se and met the same fate: dismissal.
As you’ve probably guessed, the story could have ended there, but didn’t. In September of 2007, the Executive Committee (EC) of the Northern District of Illinois issued an order prohibiting Brzowski from filing any further civil cases without leave. After Brzowski surprised exactly nobody by filing two more suits pushing the same “frivolous” argument the court had repeatedly dismissed before, the EC declared his filings “burdensome” in 2008 and ordered the court clerk to destroy anything he submitted. The EC took things a few steps further in early 2009, instructing clerks to stop taking Brzowski’s “verbally abusive and profane” phone calls.
This neatly wrapped everything up, and everyone lived happily ever after.
If only, right? Unfortunately, we all know better than that. Brzowski was undeterred and continued flooding the court with his filings, prompting the EC to extend the 2008 order in 2012. This went on for another decade, with Brzowski filing in the U.S. Court of Appeals, seeking to have certain judges removed from his cases, and fighting criminal complaints alleging violations of a protective order. In December 2021, the EC became (belatedly?) tired of Brzowski’s shenanigans and filed an order warning that further filings could incur monetary penalties, a contempt of court charge, or more filing restrictions (what comes after an order to shred? Using a flamethrower?).
That earned a “Stern Rebuttal Reply” from Brzowski that chastised the EC, claiming it “posed a threat against a U.S. private citizen.” After Brzowski failed to respond to an order to show cause as to why he shouldn’t be sanctioned, the EC fined him $500 and ordered him to comply. Nevertheless, he continued to make filings.
After another show cause was ordered on July 14, 2023, Brzowski responded about two weeks later with a "Respondents Stern Response Against the Void July 14, 2023 ‘Order’ Counter Claim of: ‘Rule to Show Cause’ Against Seventh Circuit Federal Chief Judge Rebecca R. Pallmeyer.” In addition to stating that he didn’t have to “seek out, kiss-ass permission from any brutal, vicious Federal Judge,” and that any panel he could speak before would contain “three named Federal moron” judges, Brzowski’s main subject matter involved a personal attack against then-Chief Judge Pallmeyer.
Given that angry salvo, it must have come as a bit of a surprise to the court when Brzowski filed a document on August 11 of that year called "Legal Notice to Assert July 14, 2024 Revamped Order as Valid!" that included an order by the EC (and signed by Pallmeyer) that would remove all sanctions against his filings and abolish all existing fines. Not surprisingly, the court quickly determined that Brzowski had created the fraudulent document and forged Judge Pallmeyer’s signature on it. That didn’t stop Brzowski from doing it 10 more times over the next two years, switching to the forged signature of Chief Judge Virginia M. Kendall after Pallmeyer retired.
His Picture Is Next to the Definition of “Chutzpah”
As one might expect, 11 instances of forging the signatures of federal judges eventually landed Brzowski in even more legal hot water. A federal grand jury indicted him on 11 counts in 2025, and the EC sanctioned him with a $25,000 fine for the first instance in the fraudulent document of August 11, 2023. The latter would lead to the May 11, 2026, ruling that dismissed the first count. By assessing a fine against him for the instance, the EC had essentially adjudicated the charge. Judge Simon ruled that leaving it on the docket would constitute double jeopardy in violation of the Fifth Amendment.
Any celebrations from Brzowski are likely muted, as the other ten counts of forgery are still in place. Each carries a maximum five-year sentence in a federal prison. Fifty years would give Brzowski plenty of time for additional filings, though he could also do some research if he intends to try this approach again.
Related Resources
- State Forgery Laws (FindLaw’s Learn About the Law)
- Self-Representation: The Perils of Pro Se (FindLaw’s Litigation and Disputes)
- Texas Mom Forged Law Degree With Wrong Names, Cops Say (FindLaw’s Practice of Law)
