Shallow v. United States

Shallow · United States District Court for the District of Columbia · June 16, 2026 · No. Civil Action No. 1:26-cv-01786 (UNA)

Summary

The United States District Court for the District of Columbia grants the plaintiff’s application to proceed in forma pauperis but dismisses the complaint without prejudice as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The court concludes that the allegations are irrational and lack an arguable basis in law or fact, depriving the court of subject matter jurisdiction.

Court
United States District Court for the District of Columbia
Writing for the Court
Tanya S. Chutkan
Jurisdiction
United States District Court for the District of Columbia
Decision date
June 16, 2026
Docket number
Civil Action No. 1:26-cv-01786 (UNA)
Procedural posture
The court considered Plaintiff's Complaint and application for leave to proceed in forma pauperis at the screening stage.
Standard of review
At the IFP screening stage, the court assessed whether the complaint stated a plausible claim, whether it had an arguable basis in law or fact, and whether the allegations were irrational or wholly incredible.
Precedential value
Published district court memorandum opinion; persuasive authority within the District of Columbia and nonbinding elsewhere.
Disposition
dismissed

Topics

subject matter jurisdictionpleadingscivil procedure

Practice areas

civil procedureconstitutional law

Questions Presented

  1. Whether the complaint should be dismissed as frivolous because its allegations lacked an arguable basis in law or fact and were irrational or wholly incredible.
  2. Whether the court could exercise subject matter jurisdiction over a frivolous complaint under the IFP screening statute.

Holdings

  1. The complaint was frivolous because its allegations were irrational, wholly incredible, and lacked an arguable basis in law or fact.
  2. A federal court cannot exercise subject matter jurisdiction over a complaint that is frivolous and absolutely devoid of merit.
  3. The complaint was dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B)(i).

Key quotations

The instant Complaint falls squarely into this category.
Accordingly, this matter is dismissed without prejudice.

Factual background

Plaintiff alleged that he was a DEA Group Leader and Chief of the United Nations and described purported conspiracies involving his mother, the federal government, and others. He alleged that these conspiracies were intended to murder, impersonate, attack, and falsely arrest him, steal his property, usurp him, and commit other wrongdoing. The court found the allegations difficult to understand and characterized them as irrational and wholly incredible.

Procedural history

Plaintiff filed a complaint against the United States and an application to proceed in forma pauperis. The court granted the IFP application but dismissed the complaint without prejudice under 28 U.S.C. § 1915(e)(2)(B)(i).

Court Document

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