Michael v. Trump
- Colleen McMahon
- 1:20-cv-08052
- U.S. District Court · Southern District of New York
- 4
In Michael v. Trump, Chief Judge McMahon dismissed the pro se complaint as frivolous and denied fee-free appeal status.
The dismissal ended Prince Universal Michael’s action against the named defendants. The court also denied him fee-free status for an appeal.
What happened
In Prince Universal Michael also known as Mario A. Thompson v. Donald J. Trump, Prince Universal Michael filed a 337-page complaint against thousands of defendants, including Donald J. Trump and others. He alleged many serious wrongs, including conspiracies, injuries, civil-rights violations, and copyright infringement.
The court reviewed the complaint under the rule requiring dismissal of a fee-free case that is frivolous or cannot state a valid claim. It concluded that the allegations were irrational and that no legal theory supported the claims. Because the problems could not be fixed, the court did not allow an amended complaint.
Chief Judge Colleen McMahon dismissed the complaint as frivolous. She also denied fee-free status for any appeal after certifying that an appeal would not be taken in good faith.
The detailed version
- Michael v. Trump · No. 1:20-cv-08052
- Colleen McMahon
- Oct. 15, 2020
Background
Prince Universal Michael, also known as Mario A. Thompson, sued Donald J. Trump and thousands of other defendants. The complaint was 337 pages long and named former presidents, estates of former presidents, actors, entertainers, musicians, athletes, and family members. It alleged numerous wrongs, including murder, attempted murder, human experimentation, medical malpractice, child endangerment, antitrust violations, civil-rights violations, espionage, conspiracy, trade-secret violations, defamation, and copyright infringement.
The court had previously allowed the plaintiff to proceed without paying the filing fee. This is commonly called proceeding in forma pauperis, or IFP.
Legal standard
Under 28 U.S.C. § 1915(e)(2)(B), a court must dismiss an IFP complaint if it is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant who is legally immune from that relief. The court must also dismiss a case when it lacks authority to hear the dispute. Although courts must read complaints filed without lawyers generously, a claim is frivolous when it has no reasonable basis in law or fact, including when the factual allegations are irrational or wholly incredible.
Court’s reasoning
The court stated that, even after giving the plaintiff the special consideration required for people representing themselves, the claims were irrational and had no legal theory supporting them. It therefore dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).
Courts generally give an unrepresented plaintiff a chance to amend a defective complaint. But the court explained that amendment is not required when the defects cannot be fixed. It concluded that amendment here would be futile and declined to grant leave to amend.
Disposition
Chief Judge Colleen McMahon dismissed the complaint 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 IFP status for purposes of an appeal. The clerk was directed to mail the order to the plaintiff and note service on the docket.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.