Chen v. Yale University

Background

Victor Chen, proceeding without a lawyer, sued Yale University. Although Peter Salovey was identified as Yale’s president in the caption, the complaint stated that Chen was suing only Yale University and not Salovey personally.

Chen invoked federal-question jurisdiction and asserted claims under the Fourth, Thirteenth, and Fourteenth Amendments. He alleged that, beginning in December 1949 and continuing to the present, Yale had been a “chief slaveholder” over his existence; that his living quarters had been monitored and his telephone tapped; and that his brain and body had been operated upon without his permission. He asked the court to order Yale to cooperate in confirming the history described in his writings and in revealing the truth behind other events. He also stated that he deserved compensation but was seeking mainly peace, recognition, and survival.

Screening standard

The court had previously allowed Chen to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(e)(2)(B), the court was required to dismiss a complaint filed under that status if it was frivolous or malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also noted that it had to dismiss a case if it lacked subject-matter jurisdiction. At the same time, it was required to read a self-represented litigant’s complaint liberally and interpret it to present the strongest claims reasonably suggested by the allegations.

Court’s analysis

The court concluded that Chen’s complaint had no arguable basis in law or fact. It found that his assertions about Yale’s control over his life, surveillance, and unauthorized operations lacked plausible factual support and appeared irrational. The court also found that Chen alleged no facts showing that Yale had taken action against him or held him in slavery, and that the complaint did not identify a valid legal theory under which he could proceed.

The court therefore determined that the complaint was frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). It explained that courts generally give self-represented plaintiffs an opportunity to amend defective complaints, but that amendment is not required when it would be futile. Because the court found that the defects could not be cured by amendment, it declined to grant Chen permission to amend.

Disposition

The court dismissed Chen’s complaint as frivolous. It terminated all other pending matters in the case. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied Chen permission to proceed without prepaying fees for an appeal. The opinion did not state that the dismissal was with or without prejudice.