Glenn Stephens v. President Donald Trump

Summary

A magistrate judge recommends that Glenn Stephens’s pro se complaint against President Donald Trump be dismissed without prejudice for lack of subject-matter jurisdiction. The complaint sought a writ of mandamus directing the President to order drone or missile attacks against two individuals, but the court found no alleged injury supporting Article III standing and deemed the claims wholly insubstantial and frivolous. The recommendation also concludes that amendment would be futile.

Holdings

1. The complaint failed to establish Article III standing because it alleged no concrete, particularized, actual, or imminent injury to the plaintiff.
2. The complaint should be dismissed for lack of subject matter jurisdiction because its claims were wholly insubstantial and patently frivolous.
3. Leave to amend should be denied as futile.

Questions Presented

1. Whether the complaint should be dismissed during in forma pauperis screening under 28 U.S.C. § 1915(e)(2)(B).
2. Whether the plaintiff had Article III standing and presented an actual case or controversy sufficient to establish subject matter jurisdiction.
3. Whether the complaint's allegedly wholly insubstantial and patently frivolous claims independently deprived the court of subject matter jurisdiction under the substantiality doctrine.
4. Whether the plaintiff should be granted leave to amend.

Disposition

other