“District judges have ample authority to dismiss frivolous or transparently defective suits spontaneously, and thus save everyone time and legal expense.”
How later courts described this case
- “District judges have ample authority to dismiss frivolous or transparently defective suits spontaneously, and thus save everyone time and legal expense.”
Written by the judges who cited it.
The opinion
IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF ILLINOIS
SPRINGFIELD DIVISION
Ronald Satish Emrit, )
)
Plaintiff, )
)
v. ) Case No. 26-cv-3083
)
President Barack Hussein Obama, )
et al., )
)
Defendants. )
OPINION AND ORDER
SUE E. MYERSCOUGH, U.S. District Judge:
Before the Court is Plaintiff Ronald Satish Emrit’s (“Plaintiff”)
Motion for Leave to Proceed in forma pauperis (“IFP”) (d/e 2). For the
following reasons, Plaintiff’s Motion (d/e 2) is DENIED as moot, and
the Complaint (d/e 1) is DISMISSED with prejudice.
Under 28 U.S.C. § 1915(a)(1), a federal district court may allow
a civil case to proceed without prepayment of fees if the movant
“submits an affidavit that includes a statement of all assets such
[movant] possesses that the person is unable to pay such fees or
give security therefor.” 28 U.S.C. § 1915(a)(1). However, Section
1915(e)(2) ensures careful threshold scrutiny of the complaint filed
by an IFP plaintiff by requiring the Court to dismiss any complaint
if the allegation of poverty is untrue or if the action is frivolous or
malicious, fails to state a claim upon which relief can be granted, or
seeks monetary relief against a defendant who is immune from
such relief. 28 U.S.C. § 1915(e)(2); see also Hoskins v. Pelstra, 320
F.3d 761, 763 (7th Cir. 2003) (“District judges have ample authority
to dismiss frivolous or transparently defective suits spontaneously,
and thus save everyone time and legal expense.”).
Thus, before addressing Plaintiff’s Motion for Leave to Proceed
IFP (d/e 2), the Court examines Plaintiff’s Complaint (d/e 1).
A sua sponte dismissal of a pro se IFP complaint as frivolous is
appropriate under 28 U.S.C. § 1915 if “the petitioner can make no
rational argument in law or facts to support his claim for relief.”
Jones v. Morris, 777 F.2d 1277, 1279–80 (7th Cir. 1985); see also
Neitzke v. Williams, 490 U.S. 319, 328 (1989) (noting that a court
can dismiss complaints that describe “fantastic or delusional
scenarios”). “A claim is factually frivolous if its allegations are
bizarre, irrational or incredible.” Edwards v. Snyder, 478 F.3d 827,
829 (7th Cir. 2007). A court assessing a claim under § 1915 “is not
bound, as it usually is when making a determination based solely
on the pleadings, to accept without question the truth of the
plaintiff's allegations.” Denton v. Hernandez, 504 U.S. 25, 32
(1992). A court in its discretion can “pierce the veil” of the alleged
facts and dismiss claims for factual frivolousness. Neitzke, 490 U.S.
at 327.
Plaintiff filed this action against “Former President Barack
Hussein Obama, Michelle Obama, Former President Joe Biden, Jill
Biden, Hunter Biden, Supreme Court Justice Kentanji Brown-
Jackson, Former Prince Andrew of the Windsors, and British Prime
Minister Keir Starmer” (“Defendants”). d/e 1, pp. 1-2. Plaintiff
alleges that former President Obama “is defaming the current
president by appearing in interviews and podcasts when most
former presidents try to stay out of the spotlight based on a sense of
professional courtesy” (Count I) and “has become a public nuisance
by trying to remain relevant to the modern-day political
conversation” (Count II). Id. at p. 5.
Plaintiff does not name the other seven Defendants in any of
his claims. Plaintiff alleges “companies which feature” former
President Obama on their channels, podcasts, or interviews “are
committing the tort of industrial espionage” (Count III) and
“committing the tortious interference with business
relations/contacts under the Federal Tort Claims Act (FTCA)”
(Count IV), but Plaintiff does not name any companies as
defendants. Id. Plaintiff seeks $500 billion in damages. Id. at p. 6.
Plaintiff’s allegations “make no rational argument in law or
facts to support his claim for relief.” Jones, 777 F.2d at 1279–80;
see, e.g., Fillmer v. Claims Unit Division of Risk Mgmt., No. 4:23-cv-
04183-SLD-JEH, 2024 WL 84188 (C.D. Ill. Jan. 8, 2024)
(dismissing a case as factually frivolous where plaintiff alleged he
was subjected to surveillance and harassment by government
agents appearing as voices in his head); Armstrong v. U.S. Fed.
Gov’t, No. 4:23-cv-04139-SLD-JEH, 2023 WL 7005376 (C.D. Ill.
Oct. 24, 2023) (dismissing a case as factually frivolous where
plaintiff alleged that he was a victim of mind control that caused
him to commit acts and caused incidents to happen to him); Moore
v. Roth, Nos. 90 C 1097, 90 C 1098, 90 C 1099, 90 C 1163, 90 C
1179, 90 C 1183, 90 C 1207, 90 C 1210 and 90 C 1248, 1990 WL
60735, at *1 (N.D. Ill. April 24, 1990) (“[a]llegations that some
government official has installed radiation devices in a plaintiff's . . .
brain . . . are clearly in the realm of the delusional.”).
Accordingly, Plaintiff's Complaint (d/e 1) is DISMISSED with
prejudice under 28 U.S.C. § 1915(e)(2)(B)(i). Plaintiff’s Motion for
Leave to Proceed in forma pauperis (d/e 2) is DENIED as moot. The
Court DIRECTS the Clerk to close the case and enter judgment
accordingly.
IT IS SO ORDERED.
ENTERED: March 11, 2026.
FOR THE COURT
/s/ Sue E. Myerscough
SUE E. MYERSCOUGH
UNITED STATES DISTRICT JUDGE