Olajide v. President of the United States

Background

Oladapo Olajide, proceeding without a lawyer, sued the President of the United States. The complaint sought $210 million in compensatory damages and $50 million in punitive damages. Although the court found the allegations difficult to understand, it understood Olajide to be alleging that the President conspired with the Pinole Police Department to arrest him, take custody of his child, and seize his property while he was incarcerated. Olajide also appeared to allege that he was denied equal protection based on race and religious beliefs, including an asserted right to own gold and silver. The complaint identified three causes of action under 42 U.S.C. §§ 1985 and 1986.

The defendant moved to dismiss under Federal Rule of Civil Procedure 12. Olajide responded by moving for leave to file an amended complaint.

Court’s analysis

The court addressed subject-matter jurisdiction under Rule 12(b)(1), which allows dismissal when a federal court lacks authority to hear a case. To establish standing—the requirement that a plaintiff show a concrete injury connected to the defendant’s conduct and likely to be remedied by a favorable decision—a plaintiff must show an injury in fact, traceability, and redressability. The court said it could not determine from Olajide’s allegations whether he had suffered a concrete injury or whether any injury was fairly traceable to the President.

The court also found that Olajide did not provide a factual connection between the President’s actions and the alleged injuries. The court described as nonsensical allegations that the President caused harm by approving the Gold Reserve Act of 1934, enabling federal employees to collect federal reserve notes, and failing to prevent white supremacist conspiracies.

The court further stated that, even if these problems could be overcome, the claims would likely be barred by sovereign immunity. Sovereign immunity generally protects the United States from lawsuits unless it has waived that protection. The court found no indication that the President, as a federal official, had waived it. The court also cited the principle that an action against a federal officer in an official capacity operates as a claim against the United States.

Motion to amend

The court recognized that permission to amend is generally granted liberally. But it found that Olajide’s proposed amended complaint did not correct the identified deficiencies and appeared to repeat the original allegations. The proposed complaint still did not clearly explain what happened, how Olajide was injured, or how the President was legally responsible. The court therefore denied the motion for leave to amend.

Disposition

The court granted the motion to dismiss and denied the motion to amend. It dismissed the case without leave to amend because it found that amendment would be futile. The court entered judgment in favor of the defendant and directed that the case be closed.