Tandoh v. United States
- Susan Nelson
- 0:21-cv-02451
- U.S. District Court · District of Minnesota
- 3
In Tandoh v. United States, Judge Nelson dismissed the case without prejudice for lack of jurisdiction and denied Tandoh’s fee-waiver application as moot.
Aaron Okyere Tandoh’s case was dismissed without prejudice, while the United States, Ghana, the United Kingdom, and Israel were no longer required to respond in this action.
What happened
In Tandoh v. United States, Aaron Okyere Tandoh sued the United States, Ghana, the United Kingdom, and Israel. He alleged that a public official from those nations had stalked or harassed him for many years and suggested that police departments in Edina and Virginia, Minnesota, were involved, but he did not explain the alleged conduct clearly.
The court found that the complaint was too vague and did not identify a legal basis for federal jurisdiction. It also found that the United States’ presence as a defendant prevented jurisdiction based on the parties’ citizenship. The court therefore did not reach whether Tandoh’s allegations stated a valid claim.
Judge Susan Richard Nelson dismissed the case without prejudice for lack of jurisdiction. The court denied Tandoh’s application to proceed without paying the filing fee as moot because the case was being dismissed.
The detailed version
- Tandoh v. United States · No. 0:21-cv-02451
- Susan Nelson
- Nov. 10, 2021
Background
Aaron Okyere Tandoh filed a lawsuit naming the United States, Ghana, the United Kingdom, and Israel as defendants. The complaint and its main exhibit stated that Tandoh believed he had been stalked or harassed by a public official of those nations for many years, but they did not describe what the alleged harassment involved. Tandoh also suggested that police departments in Edina and Virginia, Minnesota, were involved, without explaining how.
Tandoh did not pay the filing fee and applied to proceed without paying it based on his financial circumstances. The court found that he qualified financially for that status.
Court’s analysis
Before taking further action, the court reviewed the application under the federal statute governing cases filed without payment of fees. That statute requires dismissal when such a complaint fails to state a claim for relief. The court explained that a complaint must provide enough factual detail to make relief plausible, although complaints filed without a lawyer are read liberally.
The court found that Tandoh’s allegations were too vague and conclusory to tell the defendants what events were at issue. More importantly, the complaint did not state any basis for the court’s subject-matter jurisdiction, meaning the court’s legal authority to hear the case. Tandoh did not identify a federal-law claim, and no federal-law basis was apparent from the allegations. The court also concluded that diversity jurisdiction could not apply because the United States is not a citizen of any state for that purpose. No other jurisdictional statute appeared to apply.
Ruling
Judge Susan Richard Nelson dismissed the matter without prejudice for lack of jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court also denied Tandoh’s application to proceed without paying the filing fee as moot. The order did not decide whether the alleged stalking or harassment occurred or whether any defendant was legally responsible.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.