Garrison v. Trump

Background

Steve Garrison, an inmate in Santa Clara County Jail, filed the complaint without an attorney. He brought claims against President Donald Trump, the “Blackstone Investment Firm,” and United States District Judge James Donato. The opinion does not explain the substance of those claims. Garrison had separately been allowed to proceed without paying the filing fee.

Screening standard

The court explained that federal law requires preliminary screening of cases in which prisoners seek relief from a governmental entity or officer. The court must dismiss a complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant protected from such relief. The court also noted that these dismissal requirements apply to cases filed without paying the filing fee and are not limited to prisoner suits against government defendants. Complaints filed by people without lawyers must be read liberally.

Court’s reasoning and ruling

The court stated that the complaint repeated the same claims and allegations against the same defendants as an earlier case. Referring to the order dismissing that earlier case, the court concluded that Garrison’s claims were frivolous. It also stated that a fee-waived complaint repeating pending or previously litigated allegations and claims may be dismissed during screening.

The case was DISMISSED as both frivolous and duplicative. The clerk was ordered to enter judgment and close the file.