Jones v. United States of America

Background

Paul Conrad Everson Jones filed an “Emergency Declaration Statement [and] Complaint” and was proceeding without a lawyer. The caption named Jones, Lorelta E. Lynch, the State of Louisiana, the State of New York, the United States of America, and “America” as plaintiffs. Because Jones was the only plaintiff who signed the complaint, the court treated him as the sole plaintiff.

The complaint described incidents that Jones said occurred in and around a shelter, a deli, a gas station, and other places. He alleged assaults, harassment, theft or damage to personal items, inaction by police or shelter personnel, surveillance, interference with access to courts, and other misconduct. He attributed these events to a broad conspiracy involving federal, state, and local officials, private individuals, and others. The complaint named dozens of defendants, including agencies, officials, former presidents, Supreme Court justices, district judges, members of congressional committees, governors, and entertainers. Jones sought $350 trillion in damages, various injunctions, abolition of the federal and state governments, and criminal prosecutions.

Legal standard

Because Jones had been allowed to file without paying the filing fee, the court was required to dismiss the complaint if it was frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also had to dismiss claims over which it lacked subject-matter jurisdiction. It explained that it had to read a self-represented litigant’s filings liberally, but the complaint still had to provide enough factual detail to make a plausible claim under Rule 8 of the Federal Rules of Civil Procedure.

Court’s reasoning

The court recognized that some individual events described in the complaint—such as alleged harassment and assault by private individuals—could be plausible. But it concluded that Jones’s legal claims were ultimately based on his belief that he was the target of a widespread, multistate conspiracy. The court found that he supplied no factual basis supporting that belief. It determined that the allegations were conclusory suspicions that were not plausible and rose to the level of irrational claims. The court therefore dismissed the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

The court also denied leave to amend. It explained that amendment is generally allowed to correct defects in a self-represented litigant’s complaint, but is not required when amendment would be futile. In this case, the court found that the complaint did not suggest Jones possessed additional facts that could cure the identified defects.

Disposition

The court dismissed the complaint as frivolous. It denied Jones’s request for pro bono counsel as moot and directed the Clerk of Court to terminate all pending motions and enter judgment dismissing the action. The court certified that any appeal would not be taken in good faith and denied Jones permission to appeal without paying fees.