Nobile v. Trump

Background

Natacha Nobile proceeded without a lawyer and invoked the court’s federal-question jurisdiction. The court had previously granted her permission to proceed without prepaying filing fees. Using the court’s general complaint form, Nobile alleged that Donald Trump and others had violated her rights through death threats, defamation, business interference, and a broad conspiracy. She sought $10 billion in damages. She also filed a motion for “an order of writ and petition” to sue former President Trump.

Legal standard

Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss a complaint filed without prepaying fees if it is frivolous or malicious, fails to state a legally supportable claim, or seeks money from a defendant who is immune from that relief. The court must also dismiss claims when it lacks authority to hear them. Although courts read self-represented complaints liberally, those complaints still must provide a short and plain statement showing entitlement to relief.

Court’s reasoning

The court concluded that Nobile’s claims were based on beliefs and suspicions rather than factual support. It found that the allegations rose to the level of the irrational and were implausible and conclusory. The court therefore dismissed the complaint as frivolous under § 1915(e)(2)(B)(i). It also determined that the defects could not be cured through amendment and declined to grant leave to amend.

Disposition

The court dismissed the complaint as frivolous. It denied Nobile’s motion as moot and directed the Clerk of Court to terminate that motion. The court warned that further abuse of the privilege of filing without prepaying fees could lead to an order requiring Nobile to show cause why she should not be barred from filing new actions without prior permission. The court certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The Clerk was directed to enter judgment.