Jean-Baptiste v. United State Department of Justice

Background

Harold Jean-Baptiste, representing himself, sued the United States Department of Justice, the Federal Bureau of Investigation, and government officials. The opinion states that he filed requests under the Freedom of Information Act (FOIA) in March 2020 seeking records about alleged government monitoring and surveillance of him.

Jean-Baptiste alleged that the FBI monitored a 2022 job interview with JP Morgan Chase and told the interviewers not to hire him. He also alleged that the FBI monitored his laptop, learned about his application to St. Francis School of Law, and told someone at the school not to continue the application. He claimed that the FBI used national-security letters, violated his privacy and other rights, and targeted him because of his race, color, and national origin.

He invoked criminal statutes, the Fourth and Ninth Amendments, the Electronic Privacy Act of 1986, and 42 U.S.C. §§ 1983, 1985, and 1985(6). He sought declaratory relief, court orders requiring action, and money damages. The opinion also describes several earlier lawsuits involving the same March 2020 FOIA requests and other allegations of government monitoring, interference with employment, and harm to Jean-Baptiste.

Court’s analysis

Because Jean-Baptiste was allowed to proceed without paying filing fees, the court was required to dismiss claims that were frivolous, failed to state a claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that it had to read a self-represented party’s filings liberally, but the complaint still had to include enough facts to make a plausible claim for relief.

The court held that Jean-Baptiste’s allegations that the government was tracking him and interfering with his employment and education did not provide a factual basis or legal theory for a viable civil claim. It characterized those allegations as largely irrational or wholly incredible and dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

The court declined to interpret the amended complaint as a request for review of the denial of the March 2020 FOIA requests. It stated that Jean-Baptiste had already filed multiple complaints in different federal courts concerning those requests, so the FOIA claims were duplicative. Those claims were dismissed without prejudice.

Disposition and other orders

The court denied leave to file a second amended complaint, finding that the defects could not be cured by amendment. The court warned that further duplicative or frivolous litigation in that court could result in an order barring Jean-Baptiste from filing new actions without prior permission when seeking to proceed without paying fees.

The amended complaint was dismissed under 28 U.S.C. § 1915(e)(2)(B)(i), all outstanding matters were terminated, and the clerk was directed to enter judgment. The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.