Orly Taitz, the de facto leader of the Birthers -- the people who believe President Obama doesn't meet the Constitution's eligibility requirements for his job -- is nothing if not persistent. So she'll probably be back in court soon enough. But the fairly epic smackdown she received at the hands of a federal judge Wednesday is bound to be discouraging.

Taitz had, to her credit, come up with a pretty creative strategy. The Birther lawsuits have, thus far, run up against the problem of "standing" -- any plaintiff suing in U.S. courts must show that they have a specific injury at issue; you can't just sue over something that doesn't affect you directly. And courts have held before that the average voter doesn't have standing to sue over something like the eligibility of a presidential candidate. So Taitz has been finding members of the military who claim they're concerned that they might be following illegal orders because Obama's isn't really the president, and filing lawsuits on their behalf. (The merits of this strategy are still questionable at best, but it is at least creative.) In this case, she was representing U.S. Army Capt. Connie Rhodes, a surgeon who was fighting deployment to Iraq -- the suit was dismissed in federal court in Texas, so she brought it again in Georgia.

The problem is there were still all sorts of problems with Taitz's case. And in a scorching order dismissing the suit, United States District Judge Clay Land, a Bush appointee, let her know all about them. He also threatened her with sanctions if she files any more "similarly frivolous ... actions in this Court."

Among other things, Land pointed out that despite Taitz's claim that the president hasn't provided "satisfactory" proof of his birth in Hawaii, he has released an official document proving just that. And, he said, "Plaintiff's challenge to her deployment order is frivolous. She has presented no credible evidence and has made no reliable factual allegations to support her unsubstantiated, conclusory allegations and conjecture that President Obama is ineligible to serve as President of the United States."

Some of the choicer bits from Land's order:

Taitz's response to all this? She told a local television station that Land "should be tried for treason with Obama" and that his decision "showed a total disrespect for the Constitution of the United States of America."

Orly Taitz, one of the leaders of the Birther movement, may have finally crossed one too many lines. The courts will, after all, overlook the occasional frivolous lawsuit, even when filed by an attorney who can't get basic procedural issues right -- just the cost of doing business. But even a federal judge has a breaking point, and Clay Land appears to have reached his.

Earlier this week, Land dismissed a suit that Taitz had brought on behalf of Army Capt. Connie Rhodes, a surgeon who claimed that she couldn't follow her orders to deploy to Iraq because she's not sure President Obama is eligible, under the Constitution, to hold his current position. At the time, Land warned Taitz that if she filed any more "similarly frivolous ... actions in this Court" she'd face sanctions.

Taitz, of course, didn't seem to listen. Instead, she filed an angry motion asking Land to reconsider his decision and stay Rhodes' deployment. Apparently unaware of that old saying about catching more flies with honey than with vinegar (not true, incidentally, but that's an issue for another time), Taitz essentially accused the judge of committing treason. And, referring to the U.S. District Court on which Land serves, she wrote, "there is increasing evidence that the United States District Courts in the 11th Circuit are subject to political pressure, external control, and, mostly (sic) likely, subservience to the same illegitimate chain of command which Plaintiff has previously protested in this case, except that the de facto President is not even nominally the Commander-in-Chief of the Article III Judiciary."

For some reason, Land wasn't especially happy about this.

In an order issued Friday, Land denied Taitz's request and announced that he was considering making good on his threat of sanctions. He ordered the attorney-slash-dentist "to show cause why the Court should not impose a monetary penalty of $10,000.00 upon Plaintiff's counsel for her misconduct," and gave her 14 days to do so.

Land also took a swipe at Taitz's performance as an attorney, writing at one point that "competent counsel would have understood" one part of the law that was at issue. The implication was obvious.

In a letter to Judge Clay Land, Rhodes wrote:

This isn't the first time Taitz has done this sort of thing, despite the fact that it is -- to use the standard, complicated legal jargon -- a big no-no. Lawyers are supposed to represent their clients' wishes, not use their clients to advance their own interests, especially not without their permission.

Despite Rhodes' letter and Land's threat to fine her, Taitz appears ready to press on. In posts on her blog, she's talking about filing additional motions in the case, and she writes:

U.S. District Judge Clay D. Land is not a happy man these days. Appointed to the U.S. District Court for the Middle District of Georgia by then-President George W. Bush, Land generally has pretty important matters to consider. But lately, he's been forced to deal with Orly Taitz, the rather eccentric lawyer-slash-dentist who's become the de facto leader of the Birthers. And he wants that to stop.

To that end, on Tuesday morning Land issued a lengthy order addressing Taitz's conduct and imposing a $20,000 sanction on her as punishment for her having repeatedly filed frivolous actions and motions.

The order, which can be downloaded in PDF form here, clocks in at 43 pages and is brutal, to say the least. Land clearly anticipates an appeal, and wants to lay out his case for imposing as large a sanction as he did in order to make the facts plain and a decision easy for the appeals court. It seems, too, that he might have done this with further sanctions against Taitz in mind; he forwarded his ruling to the bar in California, where Taitz is licensed to practice.

"The Court finds that counsel's conduct was willful and not merely negligent. It demonstrates bad faith on her part. As an attorney, she is deemed to have known better," Land writes in his ruling. "She owed a duty to follow the rules and to respect the Court. Counsel's pattern of conduct conclusively establishes that she did not mistakenly violate a provision of law .... Her response to the Court's show cause order is breathtaking in its arrogance and borders on delusional. She expresses no contrition or regret regarding her misconduct .... Counsel's bad faith warrants a substantial sanction."

At one point, Land also slams Taitz for having compared herself to the late Supreme Court Justice Thurgood Marshall, who successfully argued to end school segregation in the landmark Brown v. Board of Education case. Land writes:

The whole ruling is filled with writing like this; it's striking, really, for how thoroughly Land picks Taitz and her arguments apart, and for how much time he obviously devoted to this attempt to ensure that Taitz will stop clogging the courts. As he acknowledged, though, even the sanction he imposed -- twice the $10,000 fine he originally considered -- isn't likely to stop her.

There were a lot of classic moments in U.S. District Judge Clay Land's order hitting Birther lawyer Orly Taitz with a $20,000 sanction. But there was one that stood out above all the rest, in part because it's disturbing, in part because it sums up much of the Birther movement and in part because it was just funny.

At one point in his ruling, Land -- explaining why President Obama's eligibility for his post, or lack thereof, is not a matter for the courts -- writes:

Land isn't kidding about that last part, apparently. In a footnote attached to that argument, he writes:

The story doesn't even end there. The person who wanted to fight Land apparently e-mailed Taitz herself to brag about it -- and Taitz posted the e-mail to her blog.

"I have challanged Judge Land to a round of "Fist a Cuff's" in the Couthouse Square, via E-mail... I told him that I might possibly beat some sense into him," the e-mailer wrote Taitz. "The man has insulted Me,U and 1/2 the Citizenry of the United States, by tossing ur case and calling it 'Frivolous'....No such thing as a Stupid Question, and I want to know who or what this thing in the Whitehouse is... I will let u know what Judge Land's response is..."