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S.D.N.Y.Procedural orderFiled Oct. 8, 2025

Ruff v. United States of America

Judge
Laura Swain
Docket
1:25-cv-01676
Court
U.S. District Court · Southern District of New York
Pages
5
Civil ProcedurePro Se
In one sentence

Ruff v. United States: Judge Wood dismissed Ruff’s complaint as frivolous and denied leave to amend after fee-waiver screening.

Who this affects

Bobbie Deanna Ruff’s action was dismissed, and she was denied permission to amend and fee-free status for an appeal. The claims against the United States and Steven Stebbins did not proceed.

What happened

In Bobbie Deanna Ruff v. United States of America; Steven Stebbins, Ruff sued the United States and Steven Stebbins without a lawyer. She claimed that officials and others exposed her to chemical substances, caused serious injuries, and interfered with her rights.

Ruff asserted claims under the Constitution, the “Chemical Weapons Convention,” and the “Crime of Genocide Law.” She sought accountability, protection, and medical care. The court reviewed her complaint because she had been allowed to proceed without paying filing fees.

Judge Kimba M. Wood dismissed the complaint as frivolous, meaning the allegations lacked a plausible factual basis, and denied permission to amend. The court directed the Clerk to enter judgment and denied fee-free status for any appeal.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Ruff v. United States of America · No. 1:25-cv-01676
Judge
Laura Swain
Date
Oct. 8, 2025

Background

Bobbie Deanna Ruff proceeded without a lawyer and sued the United States and Steven Stebbins, whom the opinion identifies as the Acting Inspector General for the Department of Defense. Ruff alleged that events at Ohio Health Hospital and Firelands Hospital on May 12, 2020, and October 25, 2022, involved her being exposed to a chemical weapon and suffering serious physical and cognitive injuries. She also alleged that family members, law-enforcement officers, medical professionals, lawyers, prosecutors, judges, and others were involved in attacks, harassment, stalking, or interference with justice.

Ruff asserted claims based on the United States Constitution, the “Chemical Weapons Convention,” and the “Crime of Genocide Law.” She sought accountability, protection, and medical care. The court had previously allowed her to proceed without prepaying filing fees, a status commonly called proceeding in forma pauperis (IFP).

Court’s Analysis

Under the IFP statute, the court must dismiss a complaint that is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court also must read a complaint filed without a lawyer liberally, but the complaint still must provide a short and plain statement showing entitlement to relief.

The court focused on factual frivolousness. It explained that allegations are factually frivolous when they are clearly baseless, fanciful, fantastic, or delusional, and that a plaintiff’s beliefs are not facts without plausible factual support. The court concluded that Ruff’s allegations did not have plausible factual support and appeared irrational. It therefore dismissed the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

Disposition

The court declined to give Ruff permission to amend because it concluded that she could not cure the identified defects through an amended complaint. The court directed the Clerk of Court to enter judgment dismissing the action. It also certified that any appeal would not be taken in good faith and denied IFP status for purposes of an appeal. The order was signed by Kimba M. Wood, United States District Judge.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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