Washington v. Batiah
- Laura Swain
- 1:24-cv-00563
- U.S. District Court · Southern District of New York
- 5
In Washington v. Batiah, Judge Swain dismissed Charmeen D. Washington’s complaint as frivolous and denied her leave to amend.
Charmeen D. Washington’s complaint was dismissed, affecting her claims against Metropolitan Hospital, Nicki Batiah, Charmaine Meraki, and Shelby Campbell; the court also denied fee-free appeal status.
What happened
In Washington v. Batiah, Charmeen D. Washington, representing herself, sued Metropolitan Hospital, Nicki Batiah, Charmaine Meraki, and Shelby Campbell. She alleged that events at the hospital involved medical procedures, implants, rape, suffocation, and the murder of family members, and sought justice and compensation.
The court said the complaint provided no plausible factual support and consisted of conclusory claims and suspicions. Because the allegations were irrational and frivolous under the law governing complaints filed without paying filing fees, the court dismissed the complaint.
Judge Laura Taylor Swain denied Washington leave to amend because she found the defects could not be fixed. The court terminated all other pending matters, directed the clerk to enter judgment, and denied Washington the ability to proceed without paying fees on an appeal.
The detailed version
- Washington v. Batiah · No. 1:24-cv-00563
- Laura Swain
- Apr. 15, 2024
Background
Charmeen D. Washington appeared without a lawyer and sued Metropolitan Hospital, Nicki Batiah, Charmaine Meraki, and Shelby Campbell. She used the court’s general complaint form and invoked federal-question jurisdiction, but identified the rights allegedly violated as “NEC” and “Medical Oath & Code of Honor.” She alleged that events at Metropolitan Hospital occurred in 1994, 1999, and currently. Her allegations included being wired to an “EMG voltage remote control,” having implants placed in her lungs, and suffering suffocation, theft, rape, and the murder of family members. She requested “justice and however much [she] can be compensated.”
The court had previously allowed Washington to proceed without prepaying filing fees. Under the federal law governing such cases, the court must dismiss a complaint that is frivolous, fails to state a claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court also said it must read filings by people without lawyers liberally and interpret them to raise the strongest claims they suggest.
Court’s Analysis
The court concluded that Washington’s allegations were factually frivolous. It explained that factual allegations are frivolous when they are clearly baseless, fanciful, fantastic, or delusional, and that a person’s beliefs are not facts without supporting factual allegations. The court found that Washington offered no factual basis for her assertions about procedures at Metropolitan Hospital, rape, or the murder of her family members. It characterized the allegations as conclusory claims and suspicions that did not provide a plausible factual basis for relief.
Disposition
The court dismissed Washington’s complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). It denied leave to amend because it determined that the defects could not be cured by amendment. The court terminated all other pending matters, directed the clerk to enter judgment, and certified that an appeal would not be taken in good faith. As a result, Washington was denied permission to appeal without prepaying fees. Judge Laura Taylor Swain signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.