Brown v. Trump

Background

Sharon Leslie Brown, representing herself, sued Donald Trump, Kamala Harris, Barack Obama, and Cornell West. She invoked federal-question and diversity jurisdiction and alleged that the defendants had interfered with her presidential campaigns since 2012, used or copied her campaign ideas to raise money and attract voters, and were connected to harassment and assaults. She sought money damages and an order stopping election interference and plagiarism.

The court had previously allowed Brown to proceed without paying filing fees. Under the federal statute governing such cases, the court had to dismiss the complaint if it was frivolous or malicious, failed to state a legally valid claim, sought money from an immune defendant, or presented claims over which the court lacked authority to rule. The court also explained that although filings by people without lawyers are read liberally, they still must provide a short and plain statement showing entitlement to relief.

Court’s analysis

The court concluded that Brown’s allegations were frivolous because they lacked a plausible factual basis and were irrational. It stated that Brown offered beliefs, suspicions, and a detailed narrative, but no factual basis supporting her assertions of a decade-long conspiracy, campaign interference, plagiarism, or responsibility for the alleged harassment and assaults. The court therefore dismissed the complaint under the federal fee-waiver screening statute.

The court also declined to allow amendment. It determined that the defects could not be cured by adding allegations and that Brown’s complaint did not suggest she possessed additional facts that would produce a different result.

Other matters and disposition

The court noted that Brown had previously been barred under the prisoner-filing statute from bringing federal civil actions without paying fees while incarcerated, subject to an exception for imminent danger of serious physical injury. The court also warned that continued filing of nonmeritorious cases could lead to an order restricting future fee-free civil actions in that court.

The court dismissed the action as frivolous, terminated all pending matters, and directed the clerk to enter judgment. It certified that an appeal would not be taken in good faith and denied Brown permission to appeal without paying fees. The order was signed by Louis L. Stanton, United States District Judge.