Schiff v. Trump

Summary

The United States District Court for the District of Columbia granted Graham Schiff’s application to proceed in forma pauperis and dismissed his pro se complaint without prejudice for lack of subject-matter jurisdiction. The court held that Schiff failed to allege a concrete and particularized injury supporting Article III standing, including because he challenged executive actions concerning Greenland based on a generalized grievance.

Holdings

1. The plaintiff failed to allege a concrete and particularized injury that he had sustained or was likely to sustain from defendants' alleged actions concerning Greenland, and therefore lacked Article III standing.
2. Because the plaintiff failed to allege facts sufficient to establish Article III standing, the court lacked subject-matter jurisdiction and was required to dismiss the complaint without prejudice before service.

Questions Presented

1. Whether the plaintiff sufficiently alleged Article III standing to challenge asserted executive actions concerning Greenland.
2. Whether the court had subject-matter jurisdiction over the complaint.
3. Whether the complaint should be dismissed sua sponte before service under Federal Rule of Civil Procedure 12(h)(3).

Disposition

dismissed