Baker v. Obama

Background

Eric T. Baker, who represented himself, sued Barack Hussein Obama, Joseph Robinette Biden Jr., Belcalis Almánzar, and Ramona Mazur. He requested monetary damages for alleged invasion of privacy, defamation, pain, and suffering.

Baker alleged that events began on February 4, 2021, and continued in New York State and Spain. His complaint included a document described as a “Transcript of Events: (Brain Tapping) (ETB),” a long list of terms and alleged events, claims that intellectual property had been stolen for artist development, allegations that his passport had been stolen and replaced, allegations that his keys had been stolen, and descriptions of physical ailments and conditions. The court stated that Baker did not describe how any named defendant had injured him.

Legal standard

Because Baker had been allowed to proceed without prepaying court fees, the court was required to dismiss the complaint if it was frivolous, malicious, failed to state a legally viable claim, or sought money from a defendant protected from that relief. The court also had to dismiss if it lacked authority to hear the case. It explained that a claim is frivolous when it lacks an arguable legal or factual basis, including when the alleged facts are irrational or wholly incredible. The court said it still had to read a self-represented complaint generously and consider the strongest claims suggested by the filing.

Court’s reasoning

The court held that, to the extent it could understand the complaint, it was only a list of negative events and physical ailments. It found no indication that the defendants were involved, no factual basis for the claims, and no legal theory on which Baker could rely. Even with the required generous reading of a self-represented filing, the court concluded that the claims were irrational and frivolous.

The court also considered whether Baker should be allowed to amend his complaint. It declined to grant permission to amend because it concluded that the defects could not be cured through an amended complaint.

Disposition

The court dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). It granted Baker’s motion for permission to file documents electronically. The court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied fee-free status for purposes of an appeal. The opinion does not state that the court separately entered a ruling on the underlying privacy or defamation claims beyond dismissing the action as frivolous.