Matos v. Trump

Background

Jhonensy Matos brought this action without a lawyer against Donald Trump. Matos alleged that he was a chief executive officer and had been denied “papperwork” and “pay.” He also referred to “mental abuse,” sought his “current paycheck,” and sought “an interview.” The complaint referred to Trump as the “CEO” of the “U.S.A.” Matos stated in the complaint that he was a permanent resident of the Bronx. No service had been made on Trump.

Matos’s filings gave conflicting descriptions of the basis for federal jurisdiction. On the civil cover sheet, he identified diversity jurisdiction; in the complaint, he identified federal-question jurisdiction. The complaint did not identify a statute or constitutional provision that Trump allegedly violated.

Court’s analysis

The court explained that it must read a complaint filed without a lawyer generously, but may dismiss a complaint on its own when the claims are frivolous. A claim is frivolous when it lacks a reasonable basis in fact or law.

The court found that the complaint was frivolous because its central allegations were vague and impossible to understand. It did not identify the company Matos supposedly led, explain why he should be recognized as its chief executive officer, or explain Trump’s relevance to the allegations. It also failed to provide specific facts or a clear legal basis for the claims. The court therefore concluded that it had authority to dismiss the complaint.

Disposition

The court dismissed the complaint without prejudice to filing an amended complaint. Although the court noted that some frivolous complaints should be dismissed without an opportunity to amend, it granted Matos 30 days to amend out of caution and because he was representing himself. The opinion does not state that an amended complaint was filed.