Brown v. World Health Organization
- Laura Swain
- 1:24-cv-07216
- U.S. District Court · Southern District of New York
- 4
Brown v. World Health Organization: Judge Swain dismissed Brown’s amended complaint for lack of standing and subject-matter jurisdiction.
Sharon Brown’s action was dismissed for lack of subject-matter jurisdiction. The court declined to allow another amendment, denied fee-free appellate status, and directed entry of judgment; the opinion does not impose a separate merits ruling against the named defendants.
What happened
In Brown v. World Health Organization, Sharon Brown, representing herself, sued the World Health Organization, the United Nations, António Guterres, Amnesty International, and Planned Parenthood. She alleged that the defendants had abused Israel and caused terrorism.
The court found that Brown’s complaint stated her position about Israel but did not show that any defendant caused her a personal injury that a federal court could remedy. Because she lacked standing, the court lacked authority to hear the case.
Judge Laura Taylor Swain dismissed the amended complaint for lack of subject-matter jurisdiction and declined to allow another amendment because the defects could not be fixed. The court also denied Brown’s request to proceed without paying fees for an appeal and directed the clerk to enter judgment.
The detailed version
- Brown v. World Health Organization · No. 1:24-cv-07216
- Laura Swain
- Mar. 7, 2025
Background
Sharon Brown, who was representing herself, filed this action under the court’s federal-question jurisdiction. She named the World Health Organization, the United Nations, António Guterres, Amnesty International, and Planned Parenthood as defendants. Brown alleged that the defendants had “abused Israel and caused terrorism,” made harmful blood-libel and antisemitic statements against the Bible, and tried to prevent Jews and Israel from living according to the Bible and believing in Yahweh, Elohim, and Hashem. She sought relief that included seizing assets from Egypt and Islamic countries and stopping payments to families of alleged terrorists. The complaint also contained a very large number, but the court said it was unclear whether Brown intended it as a damages request.
The court had previously allowed Brown to proceed without prepaying filing fees and had denied her request for a preliminary injunction and temporary restraining order. Brown filed an amended complaint on February 27, 2025.
Jurisdiction and standing
The court explained that the Constitution limits federal courts to actual cases and controversies. One requirement, called standing, requires a plaintiff to show a personal injury that was caused by the defendant’s conduct and could likely be remedied by the requested relief. A general disagreement or grievance shared with the public is not enough.
The court concluded that Brown’s amended complaint described her position on Israel but did not provide facts showing that any defendant caused her an actual, legally redressable injury. The court therefore found that Brown lacked standing and that it lacked subject-matter jurisdiction—the authority to hear the case.
Disposition
The court dismissed Brown’s amended complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It declined to give Brown another opportunity to amend because the defects could not be cured by amendment. The court also certified that an appeal would not be taken in good faith and denied Brown permission to proceed without prepaying fees for an appeal. It directed the clerk to enter a civil judgment.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.