Fanniegate · Pro Se Case Tracker

Joshua Angel v. United States

Five complaints. One anti-filing injunction. A motion for reconsideration filed four days later.

The pro se track most Fannie/Freddie investors aren't watching — Angel I (2018) through Angel V (2025), with both April 2026 filings hosted in full.

Complaints filed

Federal courts

8 yrs

Of litigation

Anti-filing injunction

What Just Happened

On April 23, 2026, Judge Robin M. Meriweather dismissed Angel V with prejudice and ordered the Clerk of Court to immediately enjoin Joshua Angel from filing any new documents in the Court of Federal Claims without first obtaining leave from the Chief Judge.

On April 27, 2026, four days later, Angel filed a 36-page motion for revision and reconsideration arguing the court's opinion contains a basic factual error: it states that President Trump's "implicit GUARANTEES" statement "was made prior to Angel IV's dismissal." Angel IV was dismissed June 25, 2024. Trump's statement was May 27, 2025. The Trump statement is the entire factual hook for Angel V being non-preclusive.

The court called Angel's argument "nitpicking the Court's language in the prior dismissals." Angel responds: "It is not nitpicking to expect the Court to rely on correct factual statements in determination of jurisdictional motions to dismiss."

Document 11 · Filed Apr 23 2026

Opinion and Order (Dismissal + Injunction)

⬇ Download PDF (6 pages)

Document 13 · Filed Apr 27 2026

Motion for Revision and Reconsideration

⬇ Download PDF (36 pages)

The Five Cases — Angel I Through Angel V

Angel I

2018

Angel v. Federal Home Loan Mortgage Corp., No. 1:18-cv-01142 (D.D.C. 2019), aff'd 815 F. App'x 566 (D.C. Cir. 2020)

Court: U.S. District Court, D.C. → D.C. Circuit
Defendant: FHFA, the Enterprises, and their boards

Outcome: Dismissed with prejudice; D.C. Circuit affirmed June 12, 2020

The District and Circuit decisions turned on Delaware/Virginia state-law statutes of limitation. Oral argument was denied. Angel chose not to seek rehearing.

Angel II

June 12, 2020

Angel v. United States, No. 20-cv-737 (Fed. Cl.)

Court: Court of Federal Claims
Defendant: United States

Outcome: Voluntarily dismissed August 4, 2022

First refiling against the U.S. directly, on three theories: breach of the Junior Preferred certificate of designation, breach of the implied covenant of good faith, and breach of the federal government's implicit guaranty. Parties reached a settlement-in-principle in 2021. Treasury rejected it March 2022 without explanation.

Angel III

August 8, 2022

Angel v. United States, 165 Fed. Cl. 453 (2023)

Court: Court of Federal Claims
Defendant: United States

Outcome: Dismissed without prejudice for lack of jurisdiction (statute of limitations), May 12, 2023

Expanded the case to include the $36B in MBS-litigation proceeds Treasury allegedly extracted, plus $22B of dividend entitlement. The dismissal explicitly preserved Angel's ability to refile.

Angel IV

June 1, 2023

Angel v. United States, 172 Fed. Cl. 102 (2024)

Court: Court of Federal Claims (Senior Judge Sweeney)
Defendant: United States

Outcome: Counts I-III dismissed without prejudice; Count IV (breach of Angel II settlement) dismissed with prejudice — June 25, 2024

The court reached the implicit-guaranty argument on plausibility grounds and used the words 'implausible' or 'implausibility' thirteen times. Angel's motion for reconsideration was denied June 26, 2025 — exactly one year and one day after the original dismissal. Angel's notice of appeal arrived three days late and was dismissed by the Federal Circuit January 22, 2026.

Angel V

December 1, 2025

Angel v. United States, No. 25-cv-2040 (Fed. Cl.)

Court: Court of Federal Claims (Judge Robin M. Meriweather)
Defendant: United States

Outcome: DISMISSED WITH PREJUDICE + anti-filing injunction — April 23, 2026

The new factual hook: President Trump's May 27, 2025 statement that 'the U.S. Government will keep its implicit GUARANTEES.' Angel argues this is the explicit re-affirmation that lifts the implicit-guaranty claim out of any judicial-implausibility framing. The court ruled the claims still accrued in 2013 and the six-year window expired in 2019.

The Four Arguments in Angel's April 27 Motion

Point I

DOJ misattributed the D.C. Circuit's Angel I decision to Angel II

DOJ's motion to dismiss (Dkt. 7, pages 2-3, 5, 12) repeatedly cited the D.C. Circuit's 2020 ruling in Angel I as if it had emanated from Angel II in the Court of Federal Claims. Angel I came out of D.C. District / Circuit on Delaware/Virginia state-law statute-of-limitations grounds — not 28 U.S.C. § 2501. The two are different jurisdictional analyses. Angel II was voluntarily dismissed without opinion.

Point II

The court's factual statement about Trump's tweet is wrong by ~11 months

The April 23 Opinion and Order (page 3) states: 'President Trump's statements were made prior to Angel IV's dismissal.' Angel IV was dismissed June 25, 2024. Trump's 'implicit GUARANTEES' Truth Social post was May 27, 2025. The Trump statement post-dates Angel IV by nearly eleven months — and is the entire factual basis for Angel V being non-preclusive. The court called this 'nitpicking.' Angel disagrees.

Point III

Angel II and III dismissals were non-merits and non-preclusive

Issue and claim preclusion both require a prior ruling on the merits. Angel II was voluntarily dismissed. Angel III was dismissed without prejudice. Neither dismissal can support a preclusion finding under settled doctrine. The court's reliance on these dismissals — combined with the misattributed Angel I — collapses the preclusion theory.

Point IV

Cancelling Angel's response time was procedurally improper

The court had previously granted Angel an enlargement of time to respond to DOJ's MTD until May 1, 2026. The April 23 dismissal cancelled that response window and denied a consensual second extension. Angel argues this stripped him of the chance to brief the very issues the court then resolved against him.

Frequently Asked Questions

Who is Joshua Angel?

Joshua J. Angel is a New York attorney and Fannie Mae / Freddie Mac junior preferred shareholder who has filed five pro se complaints challenging the 2012 Net Worth Sweep and its quarterly enforcement. He has practiced law for over six decades. He is also a member of the Court of Federal Claims bar — which the court cited in declining to apply the more lenient 'pro se' pleading standard. David G. Epstein (University of Richmond) is Of Counsel.

What's the anti-filing injunction?

On April 23, 2026, Judge Meriweather ordered the Clerk of Court to enjoin Angel from filing any new documents in the Court of Federal Claims without first obtaining leave from the Chief Judge. Any motion for leave must include a full complaint that explains why it is timely, properly before the court, and unrelated to any prior Angel litigation. If granted, Angel must pay the full filing fee. The court relied on O'Diah v. United States (Fed. Cir. 2018) and Bergman v. Dep't of Commerce (Fed. Cir. 1993) for authority.

Is this related to the Berkley class action / DC Circuit appeal?

No — they are parallel tracks. The Berkley / class-action case (No. 13-cv-1288 and predecessors) produced a 2022 jury verdict for shareholders that FHFA appealed to the D.C. Circuit, where oral argument took place April 21, 2026. Angel's lawsuits are separately filed pro se complaints — same underlying facts, same Net Worth Sweep, but different plaintiffs, different theories, different docket. Most of the Fannie/Freddie investor community follows the class case. Far fewer follow Angel.

What relief is Angel asking for?

Three counts in Angel V: (1) approximately $26B in quarterly contractual breaches of the junior preferred dividend rights from January 2013 to date; (2) approximately $36B in illegal exaction/extraction of Companies' MBS-Litigation Proceeds; and (3) declaratory relief under 11 U.S.C. § 1124 finding that the junior preferreds are permanently impaired and therefore mandatorily redeemable at $34B face plus interest. His April 6, 2026 settlement proposal asked for a $62B Companies' capital build via Net Worth Sweep adjustment, with ~1.5% in attorney fees, contingent on the FHFA / Treasury IPO termination proposal being filed.

What happens next?

The motion for reconsideration filed April 27, 2026 (Document 13) is now pending before Judge Meriweather. If denied, Angel's only remaining avenue is appeal to the Federal Circuit — but the anti-filing injunction stays in effect, and his prior appellate track record (the Angel IV notice of appeal arrived three days late and was dismissed) is unfavorable. If the FHFA / Treasury actually file a conservatorship-termination proposal in 2026, the implicit-guaranty argument may be resurrected by other plaintiffs in different cases.

Why is Glen tracking this?

Two reasons. First: I'm long the junior preferreds. Anything that moves the legal frame around the implicit guaranty matters to my book. Second: pro se shareholder litigation is part of the historical record of Fanniegate. Peter Chapman has been mailing me these filings for a decade. I host them, I summarize them, I keep them findable. That is a service to the community whether or not Angel ever wins.

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