Jaffe v. James
- Colleen McMahon
- 1:20-cv-02142
- U.S. District Court · Southern District of New York
- 3
In Jaffe v. James, Chief Judge McMahon dismissed Michael Jaffe’s pro se complaint as frivolous because its allegations were irrational and legally unsupported.
Michael Jaffe’s complaint was dismissed, and he was denied fee-free status for an appeal. The defendants were not required to litigate the allegations because the action was dismissed at the screening stage.
What happened
In Jaffe v. James, Michael Jaffe sued Letitia James, Andrew Cuomo, Citibank, and Hillary Clinton. He represented himself and was allowed to proceed without paying the filing fee. His complaint made allegations involving a White House tour, an arrest, large payments, the Federal Reserve, and Amazon.
The court said the allegations were irrational and that the complaint had no legal theory supporting relief. It also decided that changing the complaint would not fix its defects, so it did not allow Jaffe to amend it.
Chief Judge Colleen McMahon dismissed the complaint as frivolous under the federal filing-screening statute. The court also denied fee-free status for any appeal and warned that future frivolous or harassing lawsuits could lead to limits on Jaffe’s ability to file new cases without paying fees.
The detailed version
- Jaffe v. James · No. 1:20-cv-02142
- Colleen McMahon
- Mar. 11, 2020
Background
Michael Jaffe brought the action without a lawyer. On March 11, 2020, the court allowed him to proceed without paying the filing fee. The defendants named in the caption were Letitia James, Andrew Cuomo, Citibank, and Hillary Clinton.
Jaffe’s complaint alleged, among other things, that he went to the White House for a tour during the beginning of the Clinton administration; that Hillary Clinton promised him legal representation and arranged for him to be arrested at Queens Center Mall; that the Secret Service sent $800 million to security personnel at the mall; that Federal Reserve funds were sent to New York State; and that Amazon’s plans came from a copy of his voice. The opinion did not identify a conventional legal claim arising from these allegations.
Court’s analysis
The court applied the screening requirements for complaints filed by people who proceed without paying filing fees. Under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b), a court must dismiss a complaint that is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant protected from such relief. The court also noted that it must read a self-represented person’s allegations liberally.
The court concluded that Jaffe’s allegations were irrational and that there was no legal theory on which he could rely. It further held that the defects could not be corrected by amendment. For that reason, the court declined to give Jaffe permission to file an amended complaint.
Disposition
The court dismissed Jaffe’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B). The opinion did not state that the dismissal was with or without prejudice. 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.
The court also warned that further vexatious or frivolous litigation could result in an order barring Jaffe from filing new actions without paying fees unless he first received the court’s permission. The opinion noted that Jaffe had previously filed several complaints that were dismissed as frivolous.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.