Dickerson v. Johnson

Summary

The United States District Court for the District of Columbia grants the pro se plaintiff's motion to proceed in forma pauperis. The court dismisses the complaint without prejudice for lack of subject-matter jurisdiction, finding its allegations patently insubstantial.

Holdings

1. A court may dismiss a complaint sua sponte for lack of subject-matter jurisdiction.
2. When a complaint is patently insubstantial and presents no federal question suitable for decision, the court lacks subject-matter jurisdiction; the complaint at issue met that standard.

Questions Presented

1. Whether the district court could dismiss the complaint sua sponte for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3) and 28 U.S.C. § 1915(e)(2)(B)(i).
2. Whether allegations that were patently insubstantial and absolutely devoid of merit deprived the court of subject-matter jurisdiction.

Disposition

dismissed