Friedberg v. The United Kingdom and All the British People as Secondary
- Laura Swain
- 1:25-cv-08225
- U.S. District Court · Southern District of New York
- 6
In Donna L. Friedeberg v. The United Kingdom, Chief Judge Swain dismissed the complaint as frivolous and ordered Friedeberg to explain why an IFP filing bar should not issue.
Donna L. Friedeberg’s complaint was dismissed as frivolous. She was given 30 days to oppose a proposed bar on future fee-free civil filings in this court; the defendants were not required to respond to the dismissed complaint.
What happened
In Donna L. Friedeberg v. The United Kingdom and All the British People as Secondary, Donna L. Friedeberg alleged that every British person living in the United States was conspiring to force her into prostitution and harm her. She filed without a lawyer and without prepaying filing fees.
The court found that these allegations were irrational and that the complaint had no possible legal basis. It dismissed the action as frivolous and found that changing the complaint would not fix the problem.
Chief United States District Judge Laura Taylor Swain also gave Friedeberg 30 days to explain, in a declaration, why she should not be barred from filing future civil actions in this court without prepaying fees unless she first receives permission. The court denied fee-free status for any appeal because it certified that an appeal would not be taken in good faith.
The detailed version
- Friedberg v. The United Kingdom and All the British People as Secondary · No. 1:25-cv-08225
- Laura Swain
- Nov. 13, 2025
Background
Donna L. Friedeberg filed the action without a lawyer. The court had granted her permission to proceed without prepaying filing fees. Her complaint alleged that every British person residing in the United States had agreed to participate in a conspiracy to force her to become a prostitute and to chase, trap, and seriously injure her. The complaint included other similar allegations.
Screening and dismissal
Under the statute governing fee-free lawsuits, the court must dismiss a complaint that is frivolous, malicious, fails to state a legally sufficient claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court explained that a claim is frivolous when its factual allegations are clearly baseless, including allegations arising from delusion or fantasy, or when it relies on a legally meritless theory.
The court concluded that Friedeberg’s allegations about a conspiracy among “every British person residing in the U.S.” were irrational and that the complaint had no arguable legal or factual basis. It dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). Although courts ordinarily give a self-represented litigant an opportunity to amend, the court found that amendment would be futile and therefore did not provide leave to amend.
Order to show cause
The court stated that court records showed Friedeberg had filed more than 30 self-represented civil actions in this and other courts, which had been dismissed for substantive or procedural deficiencies. In light of that history and prior warnings, the court ordered her to show cause—that is, explain why a filing injunction should not be imposed. The proposed injunction would bar her from filing future civil actions in this court without prepaying fees unless she first obtained the court’s permission.
The court gave Friedeberg 30 days from the order to submit a declaration explaining why the injunction should not be entered. If she did not submit the declaration on time, or if it did not establish good cause, the court stated that it would impose the injunction. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.