Brown v. Columbia University
- Louis Stanton
- 1:25-cv-03213
- U.S. District Court · Southern District of New York
- 5
In Brown v. Columbia University, Judge Stanton dismissed the case for lack of standing and denied the request for emergency relief as moot.
Sharon Brown’s claims were dismissed for lack of standing; claims she tried to bring for other parties were dismissed without prejudice, and her request for preliminary emergency relief was denied as moot.
What happened
In Brown v. Columbia University, Sharon Brown sued Columbia University, Harvard University, and other broadly described schools. She alleged that schools and students promoted antisemitism, terrorism, and views about Israel, religion, gender, and sexuality that she opposed. She sought damages and orders affecting schools nationwide.
The court said Brown could represent only herself, not Israel, Jews, Christians, the United States, or other people. It also found that her complaint did not show that any defendant caused her a personal injury that a federal court could remedy. The court therefore found that she lacked standing, meaning she had not shown a personal legal injury required for a federal case.
Judge Louis L. Stanton dismissed the complaint for lack of subject-matter jurisdiction and declined to allow an amended complaint. The court dismissed without prejudice any claims Brown asserted on behalf of other parties, denied her request for an order to show cause for preliminary emergency relief as moot, and directed entry of judgment.
The detailed version
- Brown v. Columbia University · No. 1:25-cv-03213
- Louis Stanton
- June 20, 2025
Background
Sharon Brown, representing herself, sued Columbia University, Harvard University, “Home Schools,” and broadly defined public and private schools. She attempted to bring claims for herself and on behalf of “Israel, Jews and Christians, USA, [and] All parties concerned and affected.” The complaint alleged that students and schools promoted antisemitism, terrorism, and views about Israel, religion, gender, and sexuality that Brown characterized as false or harmful. Brown stated that people had been attacked, could not safely attend class or wear items identifying them as Jewish, Israeli, or American, and that education had been hindered.
Brown sought more than $1,000,000,000,000,000 in damages. She also requested orders removing university accreditation, revoking school charters and building permits, and requiring schools to include specified religious materials, music, prayer, and maps depicting Israel rather than “Palestine.” She also filed an unsigned request for an order to show cause concerning a preliminary injunction and temporary restraining order.
Court’s Analysis
Because Brown had been allowed to proceed without paying filing fees, the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B). That provision requires dismissal of an eligible complaint that is frivolous or malicious, fails to state a claim, seeks money from an immune defendant, or otherwise falls within the statute’s dismissal grounds. The court also noted that it must dismiss a case when it lacks subject-matter jurisdiction, meaning authority to decide the dispute.
The court first addressed claims Brown tried to bring for other people or entities. It held that a nonlawyer may represent only herself, not another party. The court therefore dismissed without prejudice any claims Brown asserted on behalf of another party.
The court then considered Brown’s claims on her own behalf. It explained that constitutional standing requires a plaintiff to show a personal actual or threatened injury, a connection between that injury and the defendant’s conduct, and a likelihood that the requested relief would remedy the injury. The court concluded that Brown’s allegations described her positions about Israel, religion, social issues, and education but did not provide facts showing that a defendant caused her a personal injury that a federal court could redress. The court therefore found that she lacked standing and that it lacked subject-matter jurisdiction.
The court declined to give Brown permission to amend because it concluded that the defects could not be cured by amendment. It also denied the request for an order to show cause as moot, meaning the request no longer required a ruling after the complaint was dismissed.
Disposition
Judge Louis L. Stanton dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court dismissed without prejudice the claims Brown asserted on behalf of other parties, declined to grant leave to amend, denied the request for an order to show cause as moot, and directed the Clerk of Court to enter judgment. The opinion is dated June 18, 2025, while the supplied case information lists a filing date of June 20, 2025.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.