Green v. FOX Corporation
- Laura Swain
- 1:22-cv-00243
- U.S. District Court · Southern District of New York
- 5
In Green v. FOX Corporation, Judge Swain dismissed Courtney Green’s lawsuit as frivolous and denied related requests as moot.
Courtney Green’s lawsuit was dismissed, her requests for summonses and subpoenas were denied as moot, and she received a warning that future frivolous filings could lead to a filing restriction. Fox Corporation was the defendant.
What happened
In Green v. FOX Corporation, Courtney Green, who represented herself, sued Fox Corporation for money damages. She said Fox television programs bullied and surveilled her, discussed personal matters, and collected information about her. She asserted claims including defamation and invasion of privacy and relied on diversity jurisdiction.
The court said Green’s allegations were irrational or wholly incredible and did not provide facts showing a plausible legal claim. Because the court found that changing the complaint could not fix those problems, it declined to allow an amended complaint.
Judge Swain dismissed the complaint as frivolous. She denied Green’s requests for summonses and subpoenas as moot, warned that future frivolous lawsuits could lead to a filing restriction, and denied fee-free status for an appeal.
The detailed version
- Green v. FOX Corporation · No. 1:22-cv-00243
- Laura Swain
- Apr. 4, 2022
Background
Courtney Green, appearing without a lawyer, sued Fox Corporation and requested money damages. She invoked the court’s authority to hear disputes between citizens of different states. Green said that Fox television programs, including Fox Sports and Ozark Fox, bullied and abused her, surveilled her at home, discussed her finances and living arrangements, and collected personal information. She asserted claims described as defamation, invasion of privacy, mental abuse exploitation, misuse of social status, and misuse of a media platform. The opinion states that Green resides in Missouri but does not provide a location for Fox Corporation.
The court had previously allowed Green to proceed without paying filing fees. It therefore reviewed the complaint under the statute requiring dismissal of a fee-waived complaint that is frivolous, fails to state a claim, or seeks relief from an immune defendant. The court also noted that it must dismiss a case when it lacks authority over the subject matter.
Court’s reasoning
The court concluded that the complaint was frivolous, meaning that it lacked a reasonable factual or legal basis. Even reading Green’s self-represented complaint liberally, the court found that her allegations were largely irrational or wholly incredible and did not include facts suggesting that the alleged television surveillance was possible. The court therefore determined that the allegations did not support a plausible claim for defamation, invasion of privacy, or unfair competition under New York law.
The court declined to give Green permission to amend the complaint because it found that the alleged conduct by Fox Corporation could not be made legally viable through amendment.
Disposition
The court dismissed Green’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). It denied Green’s requests for summonses and subpoenas as moot and terminated all other pending matters in the case. The court warned that additional vexatious or frivolous lawsuits in the Southern District of New York could lead to an order requiring Green to obtain permission before filing new actions. It also certified that an appeal would not be taken in good faith and denied fee-waived status for purposes of an appeal. Judge Laura Taylor Swain signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.