What is the state of the law on frivolous lawsuits?

Plainly put, the complaint was patently frivolous. See Gaskell v. Weir, 10 F.3d 626, 628 (9th Cir.1993). Moreover, it is one of multiple complaints brought against the government and based upon the self-same theories. See Zaldivar v. City of Los Angeles, 780 F.2d 823, 832 (9th Cir.1986). To be sure, this is not a case where the same plaintiff has sued over and over again, but that is a distinction without a difference. It is of an almost worse stripe because a lawyer has been able to beguile plaintiff after plaintiff into coming along with him as he rides his hobbyhorse against the government. We cannot say that the district court abused its discretion when it imposed sanctions upon Smith.