People 1 v. Williams
- Colleen McMahon
- 1:19-cv-11959
- U.S. District Court · Southern District of New York
- 3
In People #1 v. Neitzke V. Williams, Chief Judge McMahon dismissed the pro se action as frivolous and denied fee-free appeal status.
The plaintiffs’ action was dismissed, they were not allowed to amend the complaint, and fee-free status was denied for any appeal. The defendants were not required to litigate the claims on the merits.
What happened
People #1 d/b/a Juana Doe Numera Una and John/Jane Does 1-9 sued Neitzke V. Williams, other John/Jane Does, and “The Baseless Pro Se Paradox” without lawyers. They asked the court to explain the legal grounds and remedies available to people representing themselves, and described their injuries as involving time, exclusivity, and copyright.
The court had allowed the plaintiffs to proceed without paying filing fees. After reviewing the complaint, it concluded that the claims were irrational and had no legal theory supporting them. The court also found that changing the complaint would not fix the problems.
In the January 17, 2020 order, Chief United States District Judge Colleen McMahon dismissed the action as frivolous under the federal filing-fee statute and declined to allow an amended complaint. She also found that an appeal would not be taken in good faith and denied fee-free status for an appeal.
The detailed version
- People 1 v. Williams · No. 1:19-cv-11959
- Colleen McMahon
- Jan. 17, 2020
Background
The plaintiffs identified themselves as “People #1 d/b/a Juana Doe Numera Una” and “John/Jane Does 1-9.” They brought the action without lawyers and invoked federal-question jurisdiction. The court had previously granted their request to proceed without prepaying filing fees, a status commonly called proceeding “in forma pauperis.”
The plaintiffs sued “Neitzke V. Williams,” “John/Jane Doe 1-9,” and “The Baseless Pro Se Paradox.” Their complaint referred to the court’s duties toward people representing themselves and asked how such a person could lack a legal basis for claims when the court must explain what is required. The plaintiffs also questioned whether the court’s ability to examine factual allegations changes when fees are paid. They described their injuries as “2015-2020 minutes, exclusivity and copyright” and requested a written opinion identifying possible legal bases and remedies.
Legal standard
Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss an action filed without prepaying fees if it is frivolous or malicious, fails to state a legally valid claim, or seeks money from a defendant protected from that type of relief. The court must also dismiss a case when it lacks authority to hear the dispute. Even so, courts must read complaints filed by people without lawyers generously and interpret them to raise the strongest claims they reasonably suggest.
A claim is frivolous when it has no arguable basis in law or fact. The opinion explains that allegations may be factually frivolous when they are irrational or wholly incredible, or legally frivolous when they rely on a clearly meritless legal theory.
Court’s analysis
The court concluded that, even when read generously, the plaintiffs’ claims were irrational and had no legal theory on which they could rely. Although courts generally give an unrepresented plaintiff an opportunity to amend a defective complaint, the court stated that amendment would be futile here because the defects could not be cured.
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 declined to grant leave to amend. It also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied the plaintiffs permission to proceed without prepaying fees for an appeal. The clerk was directed to mail the order to the plaintiffs and record service on the docket.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.