Johnson v. Donald J. Trump

Background

Alexander Johnson, appearing without a lawyer, sued President Donald J. Trump under the court’s federal-question jurisdiction. Johnson alleged that Trump was disqualified from holding federal office under Section 3 of the Fourteenth Amendment because of his alleged conduct related to the January 6, 2021 attack on the U.S. Capitol and his later promises to pardon participants. Johnson described himself as a registered Republican voter in New York’s District 15 who participated in the 2024 presidential election.

Johnson’s complaint sought a declaration that Trump was disqualified from serving as president. He also filed an emergency motion for a temporary restraining order and preliminary injunction seeking to stop actions related to Trump’s inauguration or certification and to prevent Trump from assuming office. The court had previously allowed Johnson to proceed without prepaying filing fees.

Standing and Jurisdiction

The court explained that a plaintiff must establish standing, meaning a concrete and personal injury, a connection between that injury and the defendant’s conduct, and a likelihood that the requested relief would remedy the injury. Johnson alleged a direct interest in ensuring that only constitutionally qualified candidates held office. He also alleged that the public impact of Trump’s actions harmed voters’ rights and that he experienced stress, reduced safety, and difficulty participating in political advocacy because of threats from Trump supporters.

The court concluded that Johnson’s principal alleged injury was shared with voters nationwide and the public generally. Because Johnson did not show a concrete and particularized injury affecting him personally, the court held that he lacked standing and that it lacked subject-matter jurisdiction. The court also cited the Supreme Court’s decision in Trump v. Anderson for the proposition that Congress may enforce Section 3’s disqualification rule through legislation, and that impeachment and conviction are the primary means of removing an ineligible president from office.

Other Allegations

The court treated Johnson’s allegations about receiving vague threats from Trump supporters as a possible separate claim. It concluded that those allegations did not satisfy the requirement for a short and plain statement of a claim because Johnson named no specific supporters as defendants, asserted no claims against them, and provided insufficient facts about the threats. The court stated that this part of the allegations would fail even if Johnson could establish standing.

Disposition

Under Federal Rule of Civil Procedure 12(h)(3), the court dismissed without prejudice the complaint because it lacked subject-matter jurisdiction and Johnson lacked standing. The court denied as moot Johnson’s motions for a temporary restraining order and preliminary injunction. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith.