Young v. Trump

Background

Michael Young represented himself and filed an action under 42 U.S.C. § 1983, a federal law that permits claims for certain violations committed under state authority. He alleged that on February 26, 2004, he sent Donald Trump a letter proposing an appearance on The Apprentice involving teams competing to write country-western songs. Young alleged that, about four to six weeks later, Trump or an NBC employee stole and used the idea without permission or an invitation for Young to appear. He also alleged that Trump and Kevin Reilly were responsible for criminal and civil theft.

Young said he had sent 500 or more emails and letters about the matter since 2004. He attached a January 24, 2020, Equal Employment Opportunity Commission notice giving him permission to sue, although the notice stated that the agency considered his discrimination charge untimely. He sought damages and free legal counsel. The court had previously allowed him to proceed without prepaying filing fees.

Court’s Analysis

The court was required to review a complaint filed without prepaying fees and dismiss it if it was frivolous, failed to state a legally sufficient claim, or sought relief from an immune defendant. The court also explained that it must read a self-represented plaintiff’s allegations liberally, but the complaint still had to provide enough facts to make a claim plausible.

Civil-rights claim. Section 1983 generally requires conduct under color of state law, meaning conduct carried out through state authority. NBC Television Network and Kevin Reilly were private parties, not state or government employees. Although the complaint named Trump, it challenged his conduct as a television-show host in 2004, when he was acting as a private citizen rather than under government authority. The court therefore dismissed the Section 1983 claims for failure to state a claim.

Employment discrimination. The court considered whether Young’s allegations could state a claim under Title VII, the federal employment-discrimination law. The complaint did not allege that defendants refused to hire him or otherwise treated him differently because of race, color, religion, sex, or national origin. Instead, it alleged that they stole his songwriting idea and did not invite him to appear on the program. The court held that these allegations did not state a Title VII claim or a claim under another federal employment-discrimination statute.

Copyright. The court considered whether the allegations could be read as a copyright claim. Copyright protects original expression, but it does not protect an idea, concept, or principle by itself. Because Young alleged that defendants stole his songwriting idea, rather than protected expression, the court concluded that the allegations could not state a federal copyright claim.

Criminal allegations. Young also alleged that defendants committed criminal theft. The court held that a private person cannot direct prosecutors to bring a criminal case. It dismissed those allegations for failure to state a claim.

Amendment. The court stated that self-represented plaintiffs are generally given an opportunity to amend defective complaints, but no amendment was required when the defects could not be corrected. It therefore declined to grant Young permission to amend.

Ruling

Judge Louis L. Stanton ordered that Young’s complaint be dismissed under 28 U.S.C. § 1915(e)(2)(B)(i)-(ii). The order did not state that the dismissal was with or without prejudice. Young’s request for free legal counsel was denied as moot. The court also certified that an appeal would not be taken in good faith and denied Young permission to appeal without prepaying fees.