Garrison v. Blackstone Investment Firm

Background

Steve Garrison, an inmate in Santa Clara County Jail who was proceeding without an attorney, filed a civil complaint against “Blackstone Investment Firm,” President Donald Trump, United States District Judge James Donato, and unidentified defendants. The opinion states that Garrison was granted permission to proceed without paying the filing fee in a separate order.

The complaint included allegations that Donald Trump had ties to Blackstone’s chief executive officer and that federal judges were likely paid off. It also alleged that Judge Donato should be held responsible for murders at the United States Capitol, that he violated attorney-client privilege by failing to issue a summons, and that Blackstone, Trump, and Judge Donato conspired to violate the Saudi Royal Family’s right to due process. The complaint further alleged that federal judges were involved in murders at the Capitol and that a murder fell on Judge Donato and others, including Governor Newsom. Garrison attached a minute order from his criminal proceedings in Santa Clara Superior Court and claimed that it showed a conspiracy involving the trial judge and prosecutor to engage in human trafficking, as well as fraud by Governor Newsom.

Screening standard

The court explained that federal law requires preliminary screening of a prisoner’s civil complaint against a governmental entity or officer or employee. The court must identify claims that can proceed or dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from a defendant who is legally immune. Another federal statute separately requires dismissal of a case filed without the filing fee if the court determines that the case is frivolous, malicious, fails to state a claim, or seeks money from an immune defendant. The court also noted that it must read pleadings filed without an attorney liberally, or generously.

A claim is frivolous when it rests on an indisputably meritless legal theory or has no factual basis. The court stated that it may examine the factual allegations during this screening, but a frivolousness finding cannot be used to resolve ordinary factual disputes. Dismissal for factual frivolousness is appropriate when the alleged facts are irrational or wholly incredible, not merely unlikely.

Court’s reasoning

The court found that the allegations that President Trump, Blackstone Investment Group, and several federal judges conspired to murder people at the United States Capitol and violate the Saudi Royal Family’s right to due process were wholly incredible and delusional. It therefore found those claims frivolous under the screening statutes.

The court also found the claim based on the state-court minute order frivolous as a matter of law because the order merely identified the judge and prosecutor who handled Garrison’s case. Finally, it found the claim concerning Judge Donato’s failure to issue a summons frivolous because federal judges are immune from civil liability for acts performed in their judicial capacity, including the rulings described in the opinion.

Disposition

The court dismissed the case without leave to amend as frivolous. It ordered the clerk to enter judgment and close the file.