Doyle v. Massachusetts Institute of Technology

Background

Brian Doyle sued the Massachusetts Institute of Technology, its current and former employees, and individuals identified in the caption as using technology developed at the institute. The opinion says Doyle was proceeding without a lawyer and had been granted permission to proceed without prepaying court fees.

Using the court’s general complaint form, Doyle invoked federal-question jurisdiction and listed alleged violations involving due process, religious liberty, privacy, deprivation of life and liberty, fraud, harassment, and torture. He identified the places of occurrence as “MA, VT, NY, ME, WA, AK” and the period as approximately 2014 through 2020.

Doyle alleged that employees or people claiming to conduct research at the Massachusetts Institute of Technology had used computers and computer chips for several years to torture, threaten, and harass him. He further alleged that they claimed to have created technology capable of manipulating people’s thoughts while they were awake or asleep, and that they had threatened him and created nightmares involving disturbing sounds and images. He described spiritual, mental, and physical harm, as well as disruption to his life. He sought an order preventing the defendants from using the technology.

Court’s Analysis

Because Doyle was allowed to proceed without prepaying fees, the court applied 28 U.S.C. § 1915(e)(2)(B). That law requires dismissal of a complaint that is frivolous, malicious, fails to state a claim for relief, or seeks money from an immune defendant. The court also noted that it must dismiss a case when it lacks authority to hear the subject matter.

The court explained that it was required to read a self-represented plaintiff’s allegations generously and interpret them to raise the strongest claims reasonably suggested. Even with that approach, however, the court concluded that Doyle’s claims were irrational and had no legal theory supporting them. It therefore dismissed the action as frivolous under § 1915(e)(2)(B)(i).

Disposition

The court declined to give Doyle permission to amend because it found that the defects could not be cured by amendment. The complaint was dismissed as frivolous. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal. Judge Colleen McMahon directed the Clerk of Court to mail Doyle a copy of the order and record service on the docket.