Woodhouse v. Meta Platforms Inc.

Background

Benjamin Woodhouse, an attorney representing himself, brought this action against Meta Platforms Inc., Alphabet Inc., Nike Inc., Gibson Dunn & Crutcher Inc., and several government officials and federal judges. 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, intentional infliction of emotional distress, privacy violations involving facial-recognition technology, and treason involving alleged hacking and altered court records. Woodhouse sought damages and an injunction.

The court reviewed Woodhouse’s prior federal litigation, including cases involving his business, Havensight Capital LLC. Those earlier cases included dismissals, sanctions, findings that Woodhouse or Havensight were vexatious litigants, and filing restrictions in other courts. The court also noted that the District Court for the District of Columbia had dismissed a 2023 action involving the same defendants as frivolous.

Court’s reasoning

The court determined that the present claims were frivolous. In this context, a frivolous claim is one that lacks an arguable basis in law or fact. The court characterized Woodhouse’s allegations—including alleged conspiracies, assassination attempts, sexual abuse, and murders—as fantastic and delusional. It also concluded that the requested relief appeared to seek an improper rebuke or reversal of rulings from the Central District of California and the United States Court of Appeals for the Ninth Circuit.

Although Woodhouse was representing himself, the court declined to give him the special consideration ordinarily given to a self-represented litigant because he is an attorney. The court further found that allowing an amended complaint would be futile because no amendment concerning Woodhouse’s claims would state a legally valid claim for relief.

Ruling

The court dismissed the action as frivolous. It denied Woodhouse leave to amend. The court granted Woodhouse 30 days to show cause, by written affirmation, why it should not bar Woodhouse, Havensight, and any other entity he owns or controls from filing future civil actions in that court against any defendants named in this action without first obtaining the court’s permission. The court stated that it would impose that restriction if Woodhouse failed to respond or failed to show good cause. Defendants were not required to respond unless ordered by the court.

The court also certified that an appeal would not be taken in good faith and denied fee-free appeal status. The opinion does not state that the proposed filing restriction had already been imposed; it ordered Woodhouse to respond before deciding whether to impose it.