Epperson v. United States

Background

Chris Jonathan Epperson, who resides in Fresno, California, filed the action without a lawyer and requested permission to proceed without prepaying filing fees. He sued the United States of America; what the court understood as the United States Senate; the United States House of Representatives; the United States Government; the “Democratic Republican Party”; the United States Congress; and former Presidents Franklin D. Roosevelt, Harry S. Truman, Richard M. Nixon, and Lyndon B. Johnson.

The complaint alleged that events underlying the claims occurred at the Federal Reserve Building on December 29, 1941. It sought payments described as “500.000.000.000 Bullion to 1.7.000.000.000.000 Trillion each fiscal year” related to the operations of the United States Mint and referred to Article X of the Constitution. The complaint and supplements contained few factual allegations and included lists of statutes, regulations, court rules, and other material. One supplement appeared to seek class-action treatment, another was described as an opposition to a motion for summary judgment, and a third appeared to be a copy of an appellate brief from an unspecified case involving a former National Security Agency employee.

Rulings

The court dismissed the claims against the United States, the Senate, the House of Representatives, the United States Government, and Congress under sovereign immunity. Sovereign immunity generally prevents federal courts from hearing suits against the federal government or its branches unless immunity has been waived. The court found that Epperson alleged nothing showing a waiver and therefore dismissed those claims under the sovereign-immunity provision for claims filed without prepayment of fees and for lack of subject-matter jurisdiction.

The court also dismissed all of Epperson’s claims as frivolous, including the claims against the federal government defendants, the Democratic Republican Party, and the former presidents. It explained that a claim is factually frivolous when its allegations are clearly baseless, fanciful, fantastic, or delusional. The court found Epperson’s allegations incoherent and fantastic, leaving no factual basis or legal theory supporting a claim.

The court denied Epperson’s request to proceed as a class action because a nonlawyer representing himself cannot represent other people in a class action. It also denied leave to amend because it concluded that the defects in the complaint and supplements could not be cured by amendment. The court ordered the Clerk of Court to enter judgment dismissing the action.

Filing injunction

The court noted that an earlier order in another action had barred Epperson from filing future civil actions without prepaying fees in this court unless he first obtained permission. Because he filed this action before that injunction was entered, the court stated that the injunction did not apply to this case. The court reminded him that the injunction applies to later civil actions filed in this court in which he seeks to proceed without prepaying fees.