The Colorado Supreme Court took the extraordinary step on Tuesday of slamming the door on Nina H. Kazazian’s ability to continue flooding the legal system with “meritless” filings – conduct the state’s disciplinary authority called “paper terrorism” when it disbarred her last year.

In an unsigned opinion that did not originate from any specific court case, the justices directed the chief judge of each judicial district to reject any further filings Kazazian submits without an attorney. The Supreme Court acknowledged the Colorado Constitution protects the public’s access to the courts, but it also concluded Kazazian’s conduct threatened the administration of justice.

“We count at least fourteen times that Colorado courts have found Kazazian’s arguments, actions, or claims to be meritless. We conclude that this ‘multitude of meritless’ instances rise to the level of being intolerable,” the court wrote on Feb. 20.

The justices added that, while Kazazian may not be able to tell whether her claims are meritorious, it is more likely that she “persists merely to harass her opposers.” The opinion cited an instance where Kazazian formed a corporation in the same name of an entity to whom she owed money, then attempted to collect the payment on its behalf.

“Apart from being a fraud on the court, which led to Kazazian’s disbarment,” the Supreme Court wrote, “this particularly egregious abuse of the judicial system certainly rises to the level of harassment.”

In an email, Kazazian said the court’s decision “marks an arbitrary and troubling reversal of several longstanding tenets of law and the access to justice. The opinion seriously infringes the constitutionally protected rights to substantive and procedural due process, equal protection and the right to seek legal redress. It erases access to small claims courts and chills the right to appeal.”

Although the website for her mediation and arbitration firm lists the courts where she is admitted to practice, Kazazian does not disclose her disbarment in Colorado.

In March 2023, the Office of the Presiding Disciplinary Judge issued a detailed decision disbarring Kazazian. The panel that heard her case used blunt language in condemning what it described as Kazazian’s deception and her long-running “frivolous” legal actions across multiple jurisdictions.

“This varied, intentional, and pernicious misconduct leads us to conclude that we must impose the strongest sanction available to protect the integrity of the legal system and other litigants from any similar misconduct that Respondent may, in the future, engage in,” the disciplinary panel wrote.

Multiple attorneys and entities petitioned the Supreme Court, asking it to put a stop to Kazazian’s litigation against them. What began as a $2,360 award in Kazazian’s favor against an accounting firm that did work in her divorce case spawned a decade-long saga of lawsuits, appeals and strong words from the judges who heard her cases.

Kazazian’s behavior in a deposition was the “textbook definition of … abusive,” wrote Jefferson County District Court Judge Russell Klein.

Kazazian engaged in “stubbornly litigious and legally unjustified behavior” that “deserves no less than unequivocal condemnation,” added Judge Jerry N. Jones of the Court of Appeals.

Kazazian’s attempt to execute a settlement agreement she clearly did not enter into was “the very epitome of prosecuting an action in bad faith,” wrote former Denver District Court Judge Ross B.H. Buchanan.

The Atrium Condominium Association in Denver, which filed a brief to the Supreme Court supporting a prohibition on Kazazian’s filings, said it has been involved in more than 16 lawsuits and appeals with Kazazian.

“It is not that Ms. Kazazian, when she had a law license, practiced in an unusual or unconventional manner. It is not that attorneys opposite her have had clashes or disagreements,” wrote the association’s attorneys. “Ms. Kazazian uses the Courts to file lawsuits, motions, and even grievances to attack, punish, and harm those with whom she has come into conflict.”

Attorneys Michael G. Bohn and Armando Y. Aguilar, who originally brought the petition to the Supreme Court, alleged that by the time a new judge becomes acquainted with Kazazian’s tactics to delay or bog down cases, the damage will have been done.

Kazazian, representing herself, responded to the Supreme Court in July that she had not filed any new cases on her own since her disbarment five months earlier. She also accused the petitioners of being the aggressors against her.

“For the past decade,” Kazazian wrote, she “has consistently sought to end all disputes with these people and get away from them.”

Not so, the Supreme Court concluded.

“In the past eleven years, respondent, Nina H. Kazazian, has initiated no fewer than ten lawsuits and twice as many appeals – most of which courts have found to be duplicative, meritless, or otherwise frivolous,” the opinion read. “Now, no longer constrained by the ethical obligations of attorneys, Kazazian persists as a pro se party, creating new proceedings or prolonging old ones to continue her fruitless attempts at relitigating long-decided issues.”

Determining Kazazian’s tactics deprived “other members of the public of precious judicial resources,” it enjoined her from continuing to litigate without an attorney.

The case is GHP Horwath, P.C. et al. v. Kazazian.

This article has been updated with comments from Nina Kazazian.