Opinion

Woodhouse v. Meta Platforms Inc.

Court
District Court, District of Columbia
Filed
Jul 13, 2023
Status
Published
On the bench
Judge Amit P. Mehta
Nature of suit
Civil
Cited by
0 cases
Authority
More cited than 23.6%

noting that “a district court has the power to dismiss a case sua sponte if it is frivolous”

How later courts described this case

  • noting that “a district court has the power to dismiss a case sua sponte if it is frivolous”
  • “A court may dismiss as frivolous complaints . . . postulating events and circumstances of a wholly fanciful kind.”

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

_________________________________________

)

BENJAMIN WOODHOUSE, )

)

Plaintiff, )

)

v. ) Case No. 23-cv-01924 (APM)

)

META PLATFORMS INC., et al., )

)

Defendants. )

_________________________________________ )

MEMORANDUM OPINION

Plaintiff Benjamin Woodhouse, proceeding pro se, brings the instant action against

Defendants. 1 For the reasons stated below, the court dismisses the Complaint and this action sua

sponte.

It is well-settled that “federal courts are without power to entertain claims otherwise within

their jurisdiction if they are so attenuated and unsubstantial as to be absolutely devoid of merit,

wholly insubstantial, [or] obviously frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974)

(cleaned up). A complaint will be dismissed pursuant to Federal Rule of Civil Procedure 12(b)(1)

when it is “‘patently insubstantial,’ presenting no federal question suitable for decision.” Best v.

Kelly, 39 F.3d 328, 330 (D.C. Cir. 1994) (quoting Neitzke v. Williams, 490 U.S. 319, 327 n.6

(1989)). Claims are patently insubstantial if they are “essentially fictitious,” for example,

advancing “bizarre conspiracy theories,” “fantastic government manipulations of [one’s] will or

mind,” or some type of “supernatural intervention.” Id. at 330. In such cases, a district court

may dismiss the case sua sponte. See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008)

1

Defendants are Meta Platforms Inc., Alphabet Inc., Nike Inc., Gibson Dunn & Crutcher Inc., Attorney General Rob

Bonta, U.S. Attorney David Harris, Judge Stanley Blumenfeld, Judge Gary Klausner, Judge Christina Snyder, Judge

Dean Pregerson, Judge Lawrence Van Dyke, Judge Eric Miller, Judge Mark Bennett, Judge Joanne Osinoff, and Ninth

Circuit Clerk Molly Dwyer (each in their official capacity).

(quoting Brown v. Dist. Unemployment Comp. Bd., 411 F. Supp. 1001, 1001–02 (D.D.C. 1975)

(noting that “a district court has the power to dismiss a case sua sponte if it is frivolous”)).

Here, Plaintiff’s Complaint rests on the kind of fantastic and delusional claims that warrant

dismissal sua sponte. Specifically, Plaintiff alleges that Defendants operated a “genocide hotel”

in Pismo Beach, CA and held “impromptu death trials” in which “close to 3,000 people . . . have

been murdered.” See Compl., ECF No. 1, at 12, 14. Plaintiff also alleges a “full entourage of

commandos attempted to breach [Plaintiff’s] property and assassinate him from an uninhabited

area adjacent to [Plaintiff’s] property after helicopter insertion,” but “fortunately, [the commandos]

inadvertently incinerated themselves with napalm.” Id. at 20. Moreover, Plaintiff contends that

Defendants “imprison[ed] the Chinese Ambassador to the U.S.” in order to “stem shoe sales to

China, and leverage their coercive behavior against [Plaintiff].” Id. at 23. The court is permitted

to dismiss a complaint containing such allegations. See Neitzke, 490 U.S. at 325; see also Crisafi

v. Holland, 655 F.2d 1305, 1307–08 (D.C. Cir. 1981) (“A court may dismiss as frivolous

complaints . . . postulating events and circumstances of a wholly fanciful kind.”). Accordingly,

upon sua sponte review, this action is dismissed.

A separate final, appealable order accompanies this Memorandum Opinion.

Dated: July 13, 2023 Amit P. Mehta

United States District Judge

2

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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