Woodhouse v. Meta Platforms Inc.
- Paul Engelmayer
- 1:23-cv-07000
- U.S. District Court · Southern District of New York
- 15
In Woodhouse v. Meta Platforms, Judge Engelmayer dismissed the action as frivolous and ordered Woodhouse to explain why a filing restriction should not follow.
Benjamin Woodhouse's action was dismissed. The potential future filing restriction would apply to Woodhouse, Havensight Capital LLC, and any other entity Woodhouse owns or controls, as to future civil actions in this court against the defendants named in this action.
What happened
In Woodhouse v. Meta Platforms Inc., Benjamin Woodhouse, representing himself, sued companies, government officials, and judges. His complaint asserted claims involving alleged genocide, war crimes, racketeering, fraud, emotional distress, privacy violations, and hacking. The court noted that Woodhouse is an attorney but was representing himself.
The court dismissed the action as frivolous, meaning it lacked a reasonable basis in fact or law. It found that the allegations were clearly baseless and that the claims relied on legally meritless theories. The court also denied Woodhouse permission to amend because an amended complaint would not state a valid claim. The defendants were not required to respond unless the court later ordered them to do so.
Judge Engelmayer gave Woodhouse 30 days to explain in a written affirmation why the court should not bar him, Havensight Capital LLC, and entities he owns or controls from filing future civil actions in that court against the defendants without first obtaining permission. The court also denied the ability to appeal without paying filing fees, certifying that an appeal would not be taken in good faith.
The detailed version
- Woodhouse v. Meta Platforms Inc. · No. 1:23-cv-07000
- Paul Engelmayer
- Sept. 5, 2023
Background
Benjamin Woodhouse, an attorney representing himself, filed this action against Meta Platforms Inc., Alphabet Inc., Nike Inc., Gibson Dunn & Crutcher Inc., and various federal and state officials and judges. He sought damages and injunctive relief. The complaint asserted claims described as genocide and war crimes, violations of the Racketeer Influenced and Corrupt Organizations Act, fraud and tortious takings, impersonation of counsel and misrepresentations, intentional infliction of emotional distress, privacy violations involving facial-recognition technology, and treason involving alleged hacking and alteration of government and court records.
The court reviewed Woodhouse's and Havensight Capital LLC's earlier federal litigation, including cases involving Nike, Facebook, Alphabet, Gibson Dunn, government officials, and judges. The opinion states that several earlier actions were dismissed, and that courts had imposed sanctions, declared Woodhouse or Havensight vexatious litigants, required permission before certain filings, or otherwise restricted future litigation. The court also noted that a 2023 action by Woodhouse against the defendants in the District of Columbia had been dismissed as frivolous.
Dismissal as frivolous
A court may dismiss an action on its own initiative when the claims lack an arguable basis in fact or law. The court concluded that Woodhouse's allegations—including alleged conspiracies, assassination attempts, sexual abuse, and murders—were fantastic and delusional. It also concluded that the complaint appeared to seek review or reversal of rulings by the Central District of California and the U.S. Court of Appeals for the Ninth Circuit, which this court could not provide.
The court therefore dismissed the action on its own initiative as frivolous. It did not state that the dismissal was with or without prejudice.
Leave to amend
The court denied Woodhouse leave to amend. It found that amendment would be futile because no amended complaint concerning his claims would state a claim on which relief could be granted.
Order to show cause regarding future filings
The court directed Woodhouse to submit a written affirmation within 30 days explaining why it should not bar Woodhouse, Havensight, and any other entity he owns or controls from filing future civil actions in this court against any defendant named in this action without first obtaining the court's permission.
The court stated that, if Woodhouse did not submit the affirmation on time or failed to show good cause, it would impose that filing restriction. The order therefore directed Woodhouse to respond to a proposed filing injunction; it did not yet impose the injunction described in the order.
Other disposition
The court stated that the defendants did not need to respond unless ordered to do so. It also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees.
Read the full 15-page opinion on CourtListener, the free public archive maintained by the Free Law Project.