Dunbar v. ABC World News Network

CourtDistrict Court, S.D. New York
DecidedJune 16, 2025
Docket1:25-cv-01959
StatusUnknown

This text of Dunbar v. ABC World News Network (Dunbar v. ABC World News Network) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dunbar v. ABC World News Network, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANIS L. DUNBAR, Plaintiff, -against- 25-CV-1959 (LTS) ABC WORLD NEWS NETWORK; ROBIN ORDER OF DISMISSAL ROBERTS; MICHAEL STRAHAN; CARYN ELAINE JOHNSON, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, invokes the Court’s federal question jurisdiction. By order dated March 18, 2025, the court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. The Court dismisses the complaint for the reasons set forth below. STANDARD OF REVIEW The Court must dismiss an in forma pauperis complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). A claim is frivolous when it “lacks an arguable basis either in law or in fact.” Neitzke v.

Williams, 490 U.S. 319, 324-25 (1989), abrogated on other grounds by Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007); see also Denton v. Hernandez, 504 U.S. 25, 32-33 (1992) (holding that “finding of factual frivolousness is appropriate when the facts alleged rise to the level of the irrational or the wholly incredible”); Livingston, 141 F.3d at 437 (“[A]n action is ‘frivolous’ when either: (1) the factual contentions are clearly baseless . . . ; or (2) the claim is based on an indisputably meritless legal theory.”) (internal quotation marks and citation omitted). While the law mandates dismissal on any of these grounds, the Court is obliged to

construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief. BACKGROUND The following allegations are drawn from Plaintiff’s complaint: In 2019, I contacted these people World News CEO and the others with a 10 page letter. Later in 2021 a flyer of my True Story Book and nothing. Curtis James Jackson is my stalker sued with 25 other people there in NY.

(ECF 1 at 2.)1

Plaintiff further alleges:

In 2019, I sent the CEO and all 3 of these defendants a 10 page letter about Curtis Jackson/50 Cent. The CEO cancelled his show FOR LIFE that’s all. 2 years later I sent back a flyer of my book with his girlfriend Jamira Haines the title. And they all kept quiet. . . .What happened to New stations investigating a tip. They do world news. . . . I feel like the truth is being ignored because he’s famous and I’m not. (Id. at 5.)

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the original unless noted otherwise. Plaintiff asserts that she is suing for “defamation of character” based on the following: 50 Cent was on the View reading me commercials don’t scratch rub. He came back out rubbing his leg instead. I told a guy. He said he’s showing off for his shorty. I live on the same street my book stared what a déjà vu I want to leave now!

(Id. at 6.)

Plaintiff sues ABC Network World News, two news anchors (Robin Roberts and Michael Strahan), and a talk show host from The View, Caryn Elaine Johnson. Plaintiff contends that she has been injured because she has “been place[d] on psych holds 3 times” as a result of having been called “crazy.” (Id. at 6.)2 The Court dismissed Plaintiff’s prior suit alleging that Defendant Curtis James Jackson, III, who is known professionally as 50 Cent, has been stalking her for the past ten years as lacking any plausible factual predicate. See Dunbar v. Jackson, 24-CV-4491 (LTS) (S.D.N.Y. Sept. 5, 2024). DISCUSSION A. Subject matter jurisdiction The subject matter jurisdiction of the federal district courts is limited. Federal court jurisdiction is available only when a “federal question” is presented, 28 U.S.C. § 1331, or when plaintiff and defendant are citizens of different states and the amount in controversy exceeds $75,000, 28 U.S.C. § 1332. “[A]ny party or the court sua sponte, at any stage of the proceedings, may raise the question of whether the court has subject matter jurisdiction.” Manway Constr. Co., Inc. v. Hous. Auth. of the City of Hartford, 711 F.2d 501, 503 (2d Cir. 1983); Ruhrgas AG v.

2 On the same day that Plaintiff filed this suit, she also filed several others. See Dunbar v. Zuckerberg, No. 25-CV-1960-LTS (S.D.N.Y. filed Mar. 4, 2025); Dunbar v. Johnson, No. 25- CV-1957-LTS (S.D.N.Y. filed Mar. 4, 2025) (claims against CEO of Black Entertainment Television and others); Dunbar v. Casey, No. 25-CV-01961-LTS (S.D.N.Y. filed Mar. 4, 2025) (asserting claims about radio hosts who interacted with Curtis Jackson). Marathon Oil Co., 526 U.S. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative . . . .”). “If the court determines at any time that it lacks subject- matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3). 1. Federal Question Jurisdiction

To invoke federal question jurisdiction, a plaintiff’s claims must arise “under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. A case arises under federal law if the complaint “establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal law.” Bay Shore Union Free Sch. Dist. v. Kain, 485 F.3d 730, 734-35 (2d Cir. 2007) (quoting Empire Healthchoice Assur., Inc. v. McVeigh, 547 U.S. 677, 690 (2006)).

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Related

Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Wisconsin Department of Corrections v. Schacht
524 U.S. 381 (Supreme Court, 1998)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Empire Healthchoice Assurance, Inc. v. McVeigh
547 U.S. 677 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Johnson v. Smithsonian Institution
4 F. App'x 69 (Second Circuit, 2001)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)

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Bluebook (online)
Dunbar v. ABC World News Network, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dunbar-v-abc-world-news-network-nysd-2025.