Knight v. Obama
- Colleen McMahon
- 1:19-cv-10776
- U.S. District Court · Southern District of New York
- 3
In Knight v. Obama, Judge McMahon dismissed Angel Knight’s complaint as frivolous after screening it.
Angel Knight’s complaint was dismissed, and she was denied permission to appeal without prepaying filing fees. The opinion does not identify any other affected party beyond the defendant named in the case.
What happened
In Knight v. Obama, Angel Knight, representing herself, claimed that Carl Barrack Obama breached a verbal contract involving investments, real estate, businesses, and a 30% share of proceeds. She also listed injuries including police brutality, gunshot wounds, stalking, drug administration, departures, and jail harassment.
The court reviewed the complaint under a law requiring dismissal of certain claims filed without paying fees. It concluded that Knight’s allegations were irrational and that no legal theory supported her claim. The court also found that amending the complaint would be futile, so it declined to allow an amended complaint.
Chief United States District Judge Colleen McMahon dismissed the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The court also certified that an appeal would not be taken in good faith and denied Knight permission to appeal without prepaying fees.
The detailed version
- Knight v. Obama · No. 1:19-cv-10776
- Colleen McMahon
- Dec. 13, 2019
Background
Angel Knight, appearing without a lawyer, sued Carl Barrack Obama for breach of contract. Knight alleged that Obama offered her an opportunity to invest in a 9/11 memorial and related towers, a subway station, real estate, and small businesses. She claimed that a videotaped verbal agreement entitled her to 30% of real-estate property and ticket fees, three apartments, and 30% of businesses that were endorsed, built, and opened. She alleged that she received nothing. Knight also listed injuries including police brutality, gunshot wounds, stalking, illegal administration of drugs, departures, and jail harassment. She sought the original contract and the 30% share she said the contract provided.
Screening standard
Because Knight had been allowed to proceed without prepaying filing fees, the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B). That law requires dismissal of a claim that is frivolous or malicious, fails to state a claim, or seeks money from a defendant who is immune from such relief. The court explained that it must read a self-represented party’s allegations liberally, but a claim is frivolous when it lacks an arguable basis in law or fact, including when its factual allegations are clearly baseless or irrational or its legal theory is indisputably meritless.
Court’s analysis
The court concluded that, even when read with the special consideration given to self-represented pleadings, Knight’s claims were irrational and had no legal theory on which she could rely. The court stated that an opportunity to amend is generally provided when a self-represented complaint has defects, but amendment is not required when it would be futile. It found that the defects in Knight’s complaint could not be cured by amendment and therefore declined to grant leave to amend.
Disposition
Chief United States District Judge Colleen McMahon dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The court certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied Knight permission to appeal without prepaying filing fees. The opinion does not state that the dismissal was with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.