Seelig v. Central Intelligence Agency

Background

Christopher Michael Seelig sued the Central Intelligence Agency and other defendants. The opinion states that his claims were brought under federal criminal statutes. Magistrate Judge Thomas Hixson recommended dismissing the case without leave to amend on two independent grounds: the statutes did not provide a basis for civil liability, and the claims were frivolous.

Objections and Analysis

Seelig timely objected to the recommendation. He argued that several grounds for civil liability existed and that his claims were not frivolous. After reviewing the record and Seelig’s submissions, the court adopted the recommendation in part because the claims were frivolous. The court expressly did not decide whether the claims might arise under statutes that create civil liability. It relied on the rule that courts cannot entertain claims so insubstantial that they are completely without merit, including wholly implausible conspiracy theories.

Ruling

The court dismissed the case without leave to amend. Because the complaint was dismissed, the court denied as moot Seelig’s motion for an expedited hearing. The Clerk was directed to enter judgment and close the file. The order was signed by the judge identified in the signature block as “JON S. TIG.”