Timothy Boie v. Doe

United States District Court for the District of Massachusetts · December 9, 2025 · No. 25-cv-11402-IT

Summary

The United States District Court for the District of Massachusetts dismissed Timothy Boie’s action for lack of jurisdiction. The court concluded that Boie failed to establish Article III standing and that the United States had not waived sovereign immunity, and it terminated all pending motions as moot.

Holdings

  1. Plaintiff lacked Article III standing because he did not sufficiently allege a particularized injury arising from the allegedly false White House website information; any injury from the website's contents was too widely shared to affect him in a personal and individual way.
  2. The United States was immune from suit because Plaintiff identified no express statutory waiver of sovereign immunity applicable to his claims.

Questions Presented

  1. Whether Plaintiff alleged a concrete, particularized, actual or imminent, traceable, and redressable injury sufficient to establish Article III standing.
  2. Whether the United States waived sovereign immunity for Plaintiff's claims.
  3. Whether the action should be dismissed for lack of subject-matter jurisdiction and the pending motions terminated as moot.

Disposition

dismissed

Cases Cited (13)

  • Fideicomiso De La Tierra Del Cano Martin Pena v. Fortuno, 604 F.3d 7, 16 (1st Cir. 2010)(cited)
  • Doyle v. Huntress, Inc., 419 F.3d 3, 6 (1st Cir. 2005)(cited)
  • Pagan v. Calderon, 448 F.3d 16, 27 (1st Cir. 2006)(cited)
  • Baker v. Carr, 369 U.S. 186, 204 (1962)(cited)
  • Horne v. Flores, 557 U.S. 433, 445 (2009)(cited)
  • Spokeo, Inc. v. Robins, 578 U.S. 330, 339 (2016)(cited)
  • Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 n.1 (1992)(cited)
  • Lyman v. Baker, 954 F.3d 351, 361 (1st Cir. 2020)(cited)
  • Becker v. Federal Election Commission, 230 F.3d 381, 390 (1st Cir. 2000)(cited)
  • Food & Drug Administration v. Alliance for Hippocratic Medicine, 602 U.S. 367, 382 (2024)(cited)

Showing top 10 of 13.

Cited In (0)

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