Martinez v. Trump

Background

Anthony-Adile Martinez, who was incarcerated at Green Haven Correctional Facility, filed this pro se action, meaning he proceeded without a lawyer. He asked the court to confirm a purported arbitration award allegedly entered on August 19, 2019, in a matter involving him and Donald J. Trump, John Roberts, Nancy Pelosi, Charles Grassley, William Barr, and the United States of America.

Martinez alleged that he and the respondents had entered into a written contract involving a “conditional acceptance for value proof claim contract.” He attached the alleged contract, which the court described as plainly not a valid document. The opinion also noted that Martinez relied on a purported award from the Sitcomm Arbitration Association and cited other courts’ skepticism about that organization and its awards.

Screening standard

Because Martinez had permission to proceed without prepaying the filing fee, the court screened the complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). Those provisions require dismissal of claims that are frivolous or malicious, fail to state a claim, or seek money from a defendant protected from such relief. The court stated that a claim is frivolous when it lacks an arguable basis in law or fact, including when its factual allegations are irrational or its legal theory is indisputably meritless. The court also stated that it must read filings by people without lawyers liberally.

Court’s analysis and ruling

The court concluded that, even under the more generous standard applied to pro se filings, Martinez’s claims were irrational and had no legal theory supporting them. It specifically found his assertions that he had entered into a contract with the respondents to be frivolous.

Although courts generally give a pro se plaintiff an opportunity to amend a defective complaint, the court explained that amendment is not required when it would be futile. It found that the defects could not be cured by amendment, declined to grant leave to amend, and dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B).

The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith. It therefore denied permission to proceed without prepaying fees for an appeal. The Clerk of Court was directed to mail Martinez a copy of the order and note service on the docket.