Parsons v. The United States of America's

Background

Tyler Joseph Parsons filed the action without a lawyer and was allowed to proceed without paying the filing fee. He alleged that the defendants violated his constitutional rights to a “fair and speedy trial” after his case was dismissed. He did not identify the case he was referring to. He sought money damages, stating that he had originally claimed that between $100,000 and $200,000 was owed to him and that he later sought twice that amount.

The court reviewed its records and found that Parsons had previously filed a case alleging that his rights to “life, liberty, and the pursuit of happiness” were violated by his “being abducted and humanly trafficed.” The earlier case was dismissed as frivolous. Parsons later filed a notice of appeal, but that appeal was dismissed because he did not pay the filing fee or submit an application to proceed without paying it.

Screening standard

Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss a complaint filed without prepayment of fees if it is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant immune from that relief. The court must also dismiss when it lacks subject-matter jurisdiction. Although courts read filings by people without lawyers liberally, such complaints still must provide enough facts to make a claim plausible under Rule 8 of the Federal Rules of Civil Procedure.

Court’s analysis

The court construed Parsons’s action as an attempt to challenge Chief Judge Colleen McMahon’s dismissal of his earlier case. The complaint did not allege any conduct by members of the Executive Branch.

The court dismissed the claims against Judge McMahon and the Judicial Branch under judicial immunity and as frivolous. Judicial immunity generally protects judges from damages claims based on actions taken in their judicial roles, including rulings and actions in individual cases. The court found that McMahon’s challenged rulings and actions were within her judicial role and jurisdiction. The court also noted statutory limits on injunctive relief against a judicial officer.

The court dismissed the claims against the Executive Branch as barred by sovereign immunity and as frivolous. Sovereign immunity generally protects the United States from suit unless it has consented to be sued, and the complaint did not identify a basis for such consent.

Disposition

The court declined to give Parsons leave to amend because it concluded that the defects could not be cured by amendment. The complaint was dismissed under 28 U.S.C. § 1915(e)(2)(B). The order did not decide the merits of whether Parsons had been denied a fair or speedy trial.