Jean-Baptiste v. United States Department of Justice

Background

Harold Jean-Baptiste paid the filing fee and filed the complaint without a lawyer. He sued the United States Department of Justice, Merrick B. Garland, the Federal Bureau of Investigation, Christopher Wray, and the civil process clerk for the U.S. Attorney’s Office. He invoked multiple criminal statutes, the Fourth and Fourteenth Amendments, the Electronic Privacy Act of 1986, and 42 U.S.C. §§ 1981, 1983, 1985, and 1986. He requested declaratory relief, injunctive relief, and money damages.

Jean-Baptiste alleged that the defendants retaliated against him for filing lawsuits and participated in a broad conspiracy involving surveillance, tracking, and attempts to kidnap or kill him. He described events in 2021 and 2022 involving people, vehicles, and locations that he considered suspicious. He also attached photographs that he said showed Federal Bureau of Investigation agents, a kidnapping van, and a kidnapping team.

Court’s Analysis

The court explained that it could dismiss a fee-paid complaint if it was frivolous or if the court lacked subject-matter jurisdiction. It also noted that complaints filed without a lawyer must be read generously and interpreted to raise the strongest claims they reasonably suggest.

Even under that standard, the court found that the allegations did not plausibly show a violation of Jean-Baptiste’s rights. The court said that his belief that law-enforcement agencies and other people were conspiring against him was not supported by facts showing how he knew the alleged conspiracy existed. It characterized the allegations as conclusory claims and suspicions and found them sufficiently implausible to be frivolous.

Disposition

The court dismissed the complaint as frivolous. It found that amendment would be futile, so it did not give Jean-Baptiste permission to file an amended complaint. The court also noted that its review of the federal court records showed that Jean-Baptiste had filed upwards of 45 cases, many involving similar defendants and allegations. It stated that three other jurisdictions had already imposed filing restrictions and that Jean-Baptiste had previously been warned that similar restrictions could be imposed in this court.

The court ordered Jean-Baptiste to show cause by May 6, 2024, through a declaration, why he should not be barred from filing future actions in the court without first obtaining permission. The order states that if he failed to respond or failed to show good cause, the court would enter that filing restriction. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without paying filing fees for an appeal. The clerk was directed to keep the matter open until a civil judgment was entered.