Renaud v. Trump

Background

Stephen-Philbert Renaud, who was incarcerated at Green Haven Correctional Facility and proceeded without a lawyer, asked the court to confirm an arbitration award allegedly entered on August 19, 2019. He claimed that he and the respondents—including Donald J. Trump, John Roberts, Nancy Pelosi, Charles Grassley, William Barr, and the United States of America—had entered into a written contract. He attached a document that the court described as plainly invalid.

The court had previously granted Renaud permission to proceed without prepaying the filing fee. It then screened the complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b), which require dismissal of certain claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant.

Court’s Analysis

The court stated that a claim is frivolous when it lacks an arguable basis in law or fact. Even after giving special consideration to Renaud’s self-represented filing, the court found that his allegations about entering into a contract with the respondents were irrational and that no legal theory supported them. The opinion also noted that other courts had questioned the validity of the Sitcomm Arbitration Association, which purportedly issued the arbitration award.

The court explained that self-represented plaintiffs generally receive an opportunity to amend a defective complaint, but amendment is not required when it would be futile. It concluded that the defects in Renaud’s complaint could not be cured through amendment.

Ruling

Judge Colleen McMahon dismissed the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B). The court did not grant leave to amend. It also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The Clerk of Court was directed to mail Renaud a copy of the order and record service on the docket.