Renaud v. Trump

Background

Stephen-Philbert Renaud, who was incarcerated at Green Haven Correctional Facility and represented himself, filed an action under 42 U.S.C. § 1983 and the constitutional damages remedy recognized in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. He sued former President Donald Trump, Chief Justice John Roberts Jr., Speaker Nancy Pelosi, Senator Charles Grassley, former Attorney General William Barr, and the United States.

Renaud sought damages, injunctive relief, and confirmation of an August 19, 2019 arbitration award. His 580-page complaint referred to alleged agreements, “proofs of claims,” and “tacit acquiescence.” He also sought immediate release for himself and members of his immediate family, dismissal of legal actions against him, restrictions on government interactions and records, return of property, immunity from future civil and criminal cases, and exemption from taxes.

Screening standard and analysis

Because Renaud was a prisoner proceeding without prepayment of the filing fee, the court screened the complaint under the Prison Litigation Reform Act. The court was required to dismiss claims that were frivolous, malicious, failed to state a claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. A claim is frivolous when it lacks an arguable legal or factual basis.

The court concluded that, even when read generously because Renaud was representing himself, his claims were irrational and had no legal theory supporting them. The court also noted that the purported arbitration award attached to the complaint appeared to resolve a dispute involving a different person and awarded zero dollars per respondent for failure to state a claim. The opinion further stated that the court had previously dismissed claims arising from the same purported award as frivolous in a prior related proceeding.

Disposition

The court declined to grant leave to amend because it determined that the defects could not be cured by amendment. It dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. Chief United States District Judge Laura Taylor Swain signed the order.