Williams v. United States of America

Background

Steven Talbert Williams appeared without a lawyer and had previously been allowed to proceed without paying court fees. He alleged that the defendants violated federal constitutional and statutory rights through a broad conspiracy involving his late mother’s estate, alleged investments, a rent-stabilized apartment, financial entities, government agencies, and other matters. The complaint was 677 pages long, including exhibits, and Williams submitted additional lengthy documents after filing it.

The opinion states that Williams had previously filed two related cases involving his eviction from his late mother’s apartment, administration of her estate, and other matters. Those cases were dismissed as frivolous or for failure to state a claim, and the earlier court warned that further duplicative or frivolous litigation could lead to a restriction on fee-free filings.

Court’s Analysis

Under 28 U.S.C. § 1915(e)(2)(B), a court must dismiss a complaint filed without paying fees if it is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court must also dismiss a case when it lacks subject-matter jurisdiction. Although courts read filings by people without lawyers generously, the court concluded that Williams’s claims were irrational and had no legal theory on which he could rely.

The court also concluded that amendment would be futile, meaning that changing the complaint would not cure its defects. It therefore declined to allow Williams to amend the complaint.

Disposition

The court dismissed Williams’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The Clerk of Court was directed to terminate all pending motions. The court ordered Williams to submit, within 30 days, a declaration explaining why he should not be barred under 28 U.S.C. § 1651 from filing future actions in that court without first obtaining permission while proceeding without paying fees. The opinion says that if Williams failed to submit the declaration, or if it did not show good cause, the bar would be entered.

The court also reminded Williams that the declaration and future filings in this action were limited to 10 pages unless he first received permission to exceed that limit. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. Judge Colleen McMahon signed the order.