Sanders v. New York Times

Background

Brenda K. Sanders, who alleged that she was a licensed attorney and former Michigan state court judge, brought the action without a lawyer. The amended-complaint caption also listed Eric A. Sanders as a personal representative for the estate of Linda S. Sanders. Because Brenda Sanders alone signed the complaint and the complaint’s body identified her as the sole plaintiff, the court treated her as the only plaintiff. The court noted that the complaint did not show whether Eric Sanders could represent the estate without a lawyer.

Sanders alleged that she emailed the New York Times, the Washington Post, Fox News, ABC News, NBC News, CBS News, and 60 Minutes in 2020 and 2022. She said she reported alleged assaults by the United States military, submitted videos and other information, and reported that her twin sister, Linda Sanders, had died as a result of military attacks. She alleged that the media defendants did not respond, investigate, or publish her story, while reporting stories involving Caucasian female victims. The amended complaint referred to New York common-law claims for intentional discrimination, gross negligence, and intentional infliction of emotional distress, as well as possible breach-of-contract and intentional-interference claims. It also mentioned Title VII of the Civil Rights Act of 1964 and sought money damages.

Jurisdiction

The court first considered subject-matter jurisdiction, meaning the court’s legal authority to hear the case. Sanders invoked diversity jurisdiction, which generally requires parties to be citizens of different states and a plausible amount in controversy exceeding $75,000. The court found that she did not allege the defendants’ states of incorporation, so she failed to show complete diversity. She also asserted that the amount in controversy exceeded $75,000 but did not state the amount of damages sought or facts plausibly supporting that amount.

The court also considered federal-question jurisdiction, which applies when a claim arises under federal law. Sanders’s Title VII reference did not establish a viable federal claim because she did not allege an employment relationship with any defendant. The court further found that her other allegations, even when read generously, did not suggest a viable federal-law claim.

Frivolousness Finding

The court additionally ruled that the complaint was frivolous under the statute governing cases filed without prepaying fees. It found that Sanders’s generalized allegations that the military was trying to kill her, together with her claim that the media defendants failed to report those allegations, provided no plausible factual support for a legal claim and appeared irrational. The court also found no basis in state or federal law for the theory that a media company has a legal duty to investigate or report every news tip submitted by a private citizen.

Disposition

The court dismissed the amended complaint for lack of subject-matter jurisdiction and as frivolous. It denied leave to amend because it concluded that the claims could not be cured by amendment. The court certified that an appeal would not be taken in good faith and denied payment-free status for purposes of an appeal. It directed the Clerk of Court to enter judgment.