Arnold v. United States

Background

Marie A. Arnold sued the United States of America and the Central Intelligence Agency, which the opinion refers to collectively as Defendants. She alleged that Defendants targeted and abused her and her daughters and committed various tortious and criminal acts. The first amended complaint cited 42 U.S.C. § 2000dd, the Racketeer Influenced and Corrupt Organizations Act, the Eighth Amendment, negligent infliction of emotional distress, and fraudulent concealment. Arnold sought $10 million in damages.

Defendants’ Arguments

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which allows dismissal for lack of subject-matter jurisdiction, and Rule 12(b)(6), which allows dismissal for failure to state a legally sufficient claim. They argued that the allegations were delusional and could not establish federal jurisdiction; that the United States had not waived sovereign immunity for some claims; that no private right of action existed under 42 U.S.C. § 2000dd; that Arnold had not stated a tort claim; and that 42 U.S.C. § 1983 could not be used against the United States or its agencies.

Court’s Analysis

The court explained that federal courts lack subject-matter jurisdiction over claims that are wholly insubstantial, obviously frivolous, or otherwise completely lacking in merit as a federal controversy. It focused on allegations that Defendants used unlawful mind control, caused physical and emotional harm, used an apartment as a battlefield, and subjected Arnold and her family to electrical sensations, nail jabbing, torture, and other conduct.

The court determined that these allegations were inherently implausible and could not confer subject-matter jurisdiction. It cited other cases involving similarly implausible allegations against the United States or the Central Intelligence Agency. Because the court concluded that it lacked subject-matter jurisdiction, it did not decide Defendants’ remaining arguments.

Leave to Amend and Disposition

The court considered whether Arnold should be allowed to file another amended complaint. It found that amendment would be futile because adding more detail about the alleged mind control and related conduct would not cure the jurisdictional problem.

Judge Susan Van Keulen granted Defendants’ motion to dismiss without leave to amend. The clerk was directed to close the file. The opinion therefore classifies the ruling as a procedural disposition based on lack of subject-matter jurisdiction, rather than a decision on the underlying merits of Arnold’s claims.