Kouassi v. Trump

Background

Kouadio Kouassi proceeded without a lawyer and had been allowed to file without prepaying court fees. He alleged that he resides in Côte d’Ivoire and sued Donald Trump, identified as President of the United States, and Alassane Ouattara, identified as President of Côte d’Ivoire.

The complaint alleged that Kouassi’s intentions were observed by satellite around the world and that his reflections were being used to make movies and television programs. It also alleged that, in 2018, President Trump sent him to Côte d’Ivoire to serve as interim president, but that he was not allowed to assume that position. The complaint referred to his Social Security number, birth certificate, a political agreement concerning retirement age, mathematical formulas, Medicare, and alleged misuse of his Social Security account. Kouassi sought $40 million in damages.

Court’s analysis

Because Kouassi was proceeding without prepaying fees, the court applied the screening requirements in 28 U.S.C. § 1915(e)(2)(B). Those requirements direct a court to dismiss a complaint that is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant who is immune from such relief. The court also noted that it must dismiss a case over which it lacks subject-matter jurisdiction.

The court construed the self-represented complaint liberally, meaning it read the allegations generously when determining what claims they might raise. Even with that approach, the court concluded that the allegations did not plausibly allege a violation of Kouassi’s rights. It therefore dismissed the claims under the provisions addressing frivolous complaints and failure to state a claim.

Disposition

The court concluded that further amendment would not cure the defects in the complaint. It declined to grant leave to amend and dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The clerk was directed to enter judgment. The opinion is dated July 15, 2025.