Feng v. Tripp

Background

Yvonne Ya-Wen Feng sued Robert K. Tripp. Feng alleged that the Federal Bureau of Investigation was conspiring with the pharmaceutical industry to stalk her, poison her, and attempt to murder her to suppress a medical therapy she had invented.

On June 6, 2025, the court denied Feng’s motions for a preliminary injunction and for review under the Administrative Procedure Act. The court also granted Tripp’s motion to dismiss with prejudice. Feng then filed a motion to vacate the judgment, a motion to vacate the dismissal order, and a motion to complete or supplement the administrative record.

Motions to Vacate

The court analyzed the motions to vacate under Federal Rule of Civil Procedure 60(b), which permits relief from a final judgment for specified reasons, including mistake or excusable neglect, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or another reason justifying relief.

Feng argued that the dismissal order should be vacated because of cumulative procedural errors, an allegedly moot motion to dismiss, excluded evidence, inconsistent rulings, bias, abuse of discretion, and due-process violations. The court rejected these arguments.

The court explained that Tripp’s motion to dismiss was not moot. Although Feng had filed an amended complaint, the motion the court granted was Tripp’s second motion to dismiss, which challenged the sufficiency of that amended complaint.

The court also clarified that it had not dismissed the case for lack of standing. Instead, it had found that it lacked jurisdiction under the substantiality doctrine. The court rejected Feng’s challenges to several case-management decisions, stating that district courts have inherent authority to manage their dockets and that Feng had not identified authority showing that those decisions justified vacating the dismissal order.

The court further noted that it had considered Feng’s status as a self-represented plaintiff but determined that allowing another amendment would be futile because the court lacked jurisdiction. Finally, Feng argued that the case should have been treated as against Tripp in his official capacity rather than his individual capacity. The court concluded that Feng had not explained how that distinction affected its finding that the substantiality doctrine barred review.

Because Feng had not presented a legitimate basis for vacating the dismissal order, the court denied her motion to vacate the judgment and her motion to vacate the order.

Administrative-Record Motion

Feng also asked the court to require production of the complete administrative record relating to her immigration applications from United States Citizenship and Immigration Services and United States Immigration and Customs Enforcement.

The court denied that motion for two independent reasons. First, it had already determined that it lacked jurisdiction over the case and therefore could not grant the requested relief. Second, even if jurisdiction existed, the request was outside the scope of Feng’s amended complaint: the complaint did not name either immigration agency as a defendant and did not seek relief concerning Feng’s immigration proceedings.

Disposition

The court denied Feng’s motion to vacate the order, motion to vacate the judgment, and motion to supplement or complete the administrative record. The opinion does not add a separate prejudice designation to these denials.