Song v. President and Trustees of Columbia University in the City of New York

Background

Eugenia Song brought the action against President and Trustees of Columbia University in the City of New York and Claire Shipman, whom the opinion identifies as Columbia’s acting president. Song invoked the court’s diversity jurisdiction and proceeded without prepaying filing fees. The court had granted her request to proceed without prepayment on June 30, 2025.

Song described the action as one for libel involving her educational institution and a research associate for whom she said Peter T. Coleman was responsible. She alleged that, in May 2023, an associate contacted an Interpol-related email address, which led to contact with the administration of her Baptist seminary. She further alleged that the associate accused her, without knowledge of the matter, of having an investigative issue involving the Yale School of Management. Song sought an order directing Coleman to stay away from her and anyone around her.

Legal Standard

Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss a complaint filed without prepaying fees if it is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant who is immune from that relief. The court must also dismiss when it lacks subject-matter jurisdiction, meaning authority to hear the case. Although courts read filings by people without lawyers generously, those filings still must provide a short and plain statement showing an entitlement to relief.

A claim is frivolous when it has no arguable legal or factual basis. The court may find factual frivolousness when allegations are clearly baseless, fanciful, fantastic, delusional, or wholly incredible.

Court’s Analysis

The court concluded that Song’s allegations did not plausibly show a violation of her rights. It found that the complaint supplied no specific facts explaining how Columbia’s acting president or trustees caused harm to Song. The court stated that Song’s beliefs, however strongly held, were not facts and that the complaint offered no factual support for her assertions.

Because Song provided no plausible factual basis, the court found that her allegations rose to the level of the irrational and amounted to conclusory claims and suspicions. It therefore treated the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

Disposition

Judge Louis L. Stanton dismissed Song’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The court declined to grant leave to amend because it found that the defects could not be cured by amendment. It directed the Clerk of Court to enter judgment.

The court also stated that a warning issued in an earlier related proceeding remained in effect. It warned that, if Song filed future actions in that court that were frivolous or failed to state a claim against the named defendants, the court could bar her from filing new actions without prepaying fees unless she obtained permission to file.