Brown v. United Nations

Background

Sharon Brown appeared without a lawyer and invoked the court’s federal-question jurisdiction. She alleged that the defendants violated her rights to life, freedom of speech, the right to bear arms, self-defense, and freedom of religion. She purported to bring the action on behalf of Israel, “unborn babies,” “all people who have a right to life,” the God of the Bible, Yahweh, Elohim, Hashem, Jesus Christ, and the Holy Spirit.

The defendants named in the complaint were the United Nations, the World Health Organization, the United Nations Relief and Works Agency for Palestine Refugees in the Near East, the presumed New York State Office of Mental Health, Planned Parenthood, and the “abortion industry.” Brown’s allegations addressed abortion, Israel, Islam, school shootings, religion in schools, and other subjects. She sought, among other things, reparations for Israel and money from Islamic governments.

Standing and jurisdiction

The court explained that federal courts may decide only actual cases or controversies. To establish standing, a plaintiff must show a personal actual or threatened injury, a connection between that injury and the defendants’ conduct, and a likelihood that the requested relief would remedy the injury. A generalized grievance—one shared broadly with the public—is not enough.

The court found that Brown’s complaint expressed her positions on abortion, Israel, and Islam but did not provide facts showing that any defendant caused her an actual injury that a federal court could remedy. The court therefore concluded that Brown lacked standing and that it had no subject-matter jurisdiction over the action.

Disposition

The court dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It declined to grant leave to amend because it found that the defects could not be cured by amendment.

The court denied as moot Brown’s request for preliminary injunctive relief and a temporary restraining order. It also certified that any appeal would not be taken in good faith and denied Brown fee-free status for purposes of an appeal. The clerk was directed to enter a civil judgment.