Summary
The United States District Court for the District of Columbia grants the pro se plaintiff leave to proceed in forma pauperis but dismisses his complaint without prejudice as frivolous and lacking subject-matter jurisdiction. The court also denies as moot the plaintiff’s motion to admit federal code violations.
Topics
Practice areas
Questions Presented
- Whether the complaint stated a plausible claim for relief or was frivolous because its allegations were irrational, wholly incredible, or fanciful.
- Whether the district court could exercise subject matter jurisdiction over the complaint.
- Whether plaintiff's motion to admit federal code violations remained justiciable after dismissal of the complaint.
Holdings
- A complaint must be dismissed as frivolous when its factual allegations rise to the level of the irrational, wholly incredible, or wholly fanciful; plaintiff's allegations met that standard.
- Federal courts lack power to entertain claims that are otherwise within their jurisdiction when the claims are so attenuated and unsubstantial as to be absolutely devoid of merit; the complaint therefore could not support subject matter jurisdiction.
- The motion to admit federal code violations was denied as moot after dismissal of the complaint.
Key quotations
“A complaint that lacks “an arguable basis either in law or in fact” is frivolous”
“Indeed, as here, a court is obligated to dismiss a complaint as frivolous “when the facts alleged rise to the level of the irrational or the wholly incredible,””
“The Court cannot exercise subject matter jurisdiction over Plaintiff’s frivolous Complaint.”
Factual background
Plaintiff, who was civilly committed at Butner Federal Medical Center, alleged that while working as a freelance consultant in 2020 he witnessed an illegal effort to falsify the presidential election through control of election computers. He further alleged that, after attempting to notify Congress, unidentified bad actors poisoned him twice, prevented medical providers from treating him, and caused him to be unfairly arrested. He sought $39 billion in damages and failed to provide addresses for many defendants.
Procedural history
Plaintiff filed a pro se complaint alleging that various defendants participated in a scheme to falsify the 2020 presidential election and subsequently poisoned and unlawfully arrested him. The court granted plaintiff leave to proceed in forma pauperis, conducted its initial review, dismissed the complaint without prejudice, and denied as moot plaintiff's motion to admit federal code violations.