finding that appellant “cannot state a claim under the Universal Declaration of Human Rights or the Vienna Declaration because both are non-binding declarations that provide no private rights of action”
How later courts described this case
- finding that appellant “cannot state a claim under the Universal Declaration of Human Rights or the Vienna Declaration because both are non-binding declarations that provide no private rights of action”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LEWIS ROSS BROWN, )
)
Plaintiff, )
)
v. ) Civil Action No. 22-1708 (UNA)
)
TESSA L. BURMANIA et al., )
)
Defendants. )
MEMORANDUM OPINION
Lewis Ross Brown, a former employee of the Environmental Protection Agency, alleges
that defendants “blacklisted [him] from employment within the Federal Government after [he]
was removed for exercising [his] right to file an EEO Complaint and to report [defendants’]
misconduct . . . to the Agency OIG” and others. Compl. at 3, Dkt. 1. He purports to bring this
action under the Universal Declaration of Human Rights. See id. His claim fails because the
Declaration does not provide a private right of action. See Sosa v. Alvarez–Machain, 542 U.S.
692, 734 (2004) (“[T]he Declaration does not of its own force impose obligations as a matter of
international law.”); Vizi v. Outback Steakhouse, 672 F. App’x 168, 171 n.1 (3d Cir. 2016) (per
curiam) (finding that “Universal Declaration of Human Rights . . . is a nonbinding declaration
that provides no private rights of action”); Konar v. Illinois, 327 F. App’x 638, 640 (7th Cir.
2009) (finding that appellant “cannot state a claim under the Universal Declaration of Human
Rights or the Vienna Declaration because both are non-binding declarations that provide no
private rights of action”); Perry v. Frederick, No. 22-CV-1973, 2022 WL 1810713, at *1 n.3
(E.D. Pa. June 2, 2022) (recognizing Third Circuit’s ruling in United States v. Chatman, 351 F.
App’x 740, 741 (3d Cir. 2009), that “the Universal Declaration of Human Rights is a non-
binding declaration that provides no private rights of action”).
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The Court will grant plaintiff’s application to proceed in forma pauperis and, for the
reasons stated above, dismiss the complaint and this civil action. An Order is issued separately.
DATE: June 21, 2022 /s/
DABNEY L. FRIEDRICH
United States District Judge
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