Emrit v. United States Patent and Trademark Office

CourtDistrict Court, E.D. Michigan
DecidedApril 23, 2025
Docket4:25-cv-11088
StatusUnknown

This text of Emrit v. United States Patent and Trademark Office (Emrit v. United States Patent and Trademark Office) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emrit v. United States Patent and Trademark Office, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

RONALD SATISH EMRIT, et al., Case No. 25-cv-11088

Plaintiff, F. Kay Behm v. U.S. District Judge

UNITED STATES PATENT AND TRADEMARK OFFICE, et al.,

Defendants. ___________________________/

OPINION AND ORDER DISMISSING COMPLAINT (ECF No. 1) WITHOUT PREJUDICE AND ENJOINING FILER UNDER LR 5.2

Plaintiff, Ronald Satish Emrit, filed this complaint on April 15, 2025, against a number of defendants, including the United States Patent and Trademark Office (USPTO), United States Department of Commerce, NASA, the Kennedy Space Center, the American Institute of Physics, and the National Science Foundation, seeking 1) a design and utility patent without having to go through the “red tape” of obtaining a patent, ECF No. 1, PageID.12, 2) recognition of his theories of “quantum mechanics and astrophysics even though there is no mathematical proof for these ideas,” id. at PageID.13, and 3) damages for unspecified tortious interference with a contract and business relations, id. at PageID.10-11. He also filed an application to proceed in

forma pauperis, which this court GRANTS. (ECF No. 2). For the reasons set forth below, the court DISMISSES the complaint without prejudice under 28 U.S.C. § 1915(e) and Fed. R. Civ. P 12(b)(1) because

this court lacks subject matter jurisdiction and his complaint fails to state a claim on which relief may be granted. A district court “may, at any time, sua sponte dismiss a complaint

for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure when the allegations of a complaint are totally implausible, attenuated, unsubstantial, frivolous, devoid of

merit, or no longer open to discussion.” Apple v. Glenn, 183 F.3d 477, 479 (6th Cir.1999) (citing Hagans v. Lavine, 415 U.S. 528, 536–537, 94 S.Ct. 1372 (1974)); see also In re Bendectin Litig., 857 F.2d 290, 300 (6th

Cir. 1988) (recognizing that federal question jurisdiction is divested by obviously frivolous and unsubstantial claims.). Further, under 28 U.S.C. § 1915(e), a district court is required to screen for, and sua

sponte dismiss as frivolous, claims brought by pro se litigants proceeding in forma pauperis based on an indisputably meritless legal theory and claims whose factual contentions are clearly baseless. See Gifford v. Grassley, No. 20-10762, 2020 WL 4006845, at *2 (E.D. Mich.

Apr. 6, 2020), report and recommendation adopted, No. 20-10762, 2020 WL 2028572 (E.D. Mich. Apr. 28, 2020); Neitzke v. Williams, 490 U.S. 319, 109 (1989). “Within the former category fall those cases in which

either it is readily apparent that the plaintiff’s complaint lacks an arguable basis in law or that the defendants are clearly entitled to immunity from suit; within the latter are those cases describing

scenarios clearly removed from reality.” Sultenfuss v. Snow, 894 F.2d 1277, 1278 (11th Cir. 1990); see Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013); Barnaby v. Mayfield, No. 20-1564, 2021 U.S. App. LEXIS

13422, at *2-3 (6th Cir. May 5, 2021) (citing Hill v. Lappin, 630 F.3d 468, 470-71 (6th Cir. 2010)). A complaint is also frivolous and can be dismissed if it provides no basis for federal jurisdiction. Carlock v.

Williams, 182 F.3d 916, 1999 WL 454880, at *2 (6th Cir. 1999) (“Since there is no basis for federal jurisdiction apparent on the face of Carlock’s complaint . . . the district court properly dismissed the action

as frivolous and for lack of subject matter jurisdiction.”) (citing 28 U.S.C.A. § 1915(e)(2)(B); Fed. R .Civ. P. 12(h)(3)). Under Federal Rule of Civil Procedure 8(a)(1), all pleadings – even those brought pro se – must properly invoke the jurisdiction of the federal courts by “short and

plain statement of the grounds for the court’s jurisdiction.” Finally, a court must dismiss any claim on which relief may not be granted. 28 U.S.C. § 1915(e)(2)(B)(ii).

In considering whether a complaint should sua sponte be dismissed for lack of subject matter jurisdiction or that it lacks a basis in law under § 1915(e), the court is especially mindful that a pro se

litigant’s complaint is to be construed liberally. Dekoven v. Bell, 140 F. Supp. 2d 748, 754 (E.D. Mich. 2001) (citing Middleton v. McGinnis, 860 F. Supp. 391, 392 (E.D. Mich. 1994). Further, “because access to the

courts is essential to the enforcement of laws and protection of the values that are rooted deeply in our democratic form of government, this Court may not treat lightly the claims of any litigant, even those

whose contentions appear fantastic and baseless on their face.” Dekoven, 140 F.Supp.2d at 754. Thus, every complaint is “entitled to a thorough review to determine whether it has merit and states a

federally cognizable claim.” Id. However, a plaintiff, even proceeding pro se, must still “plead factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). After a thorough and careful review of Plaintiff’s complaint, taking all allegations as true and construing them liberally, Plaintiff

fails to invoke this court’s subject matter jurisdiction or state a claim on which relief may be granted. The claims in Plaintiff’s complaint that might arise under federal law have no plausibility and lack any

arguable basis in law or fact. See Emrit v. USPTO, 25-cv-00720, ECF No. 3 (E.D. La. Apr. 17, 2025) (dismissing this exact same complaint brought in that district, and discussing in detail the lack of any merit or

plausibility to his allegations). To the extent that the Complaint is coherent at all,1 when viewed liberally and in the light most favorable to Plaintiff, it appears that he seeks to “avoid the red tape” of United

States patent law, and have this court grant him a patent and require the government and various agencies to adopt his ideas regarding quantum mechanics, astrophysics, general relativity, and special

relativity. But even assuming for a moment that the court could enter

1 For example, “[f]or reasons neither explained by Plaintiff nor understandable as written, Plaintiff [] spends four pages of the Complaint apparently including links to music videos.” Emrit v. USPTO, 25-cv-00720, ECF No. 3 (E.D. La. Apr. 17, 2025). any part of such an extraordinary order, his “theories” lack any facial

plausibility and the factual basis of his claims is frivolous. See e.g., Complaint, ECF No. 1, PageID.5-6 (“The plaintiff’s music video . . .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hagans v. Lavine
415 U.S. 528 (Supreme Court, 1974)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
In Re Bendectin Litigation.
857 F.2d 290 (Sixth Circuit, 1988)
Thomas L. Apple v. John Glenn, U.S. Senator
183 F.3d 477 (Sixth Circuit, 1999)
Dawn Ball v. Famiglio
726 F.3d 448 (Third Circuit, 2013)
Middleton v. McGinnis
860 F. Supp. 391 (E.D. Michigan, 1994)
Dekoven v. Bell
140 F. Supp. 2d 748 (E.D. Michigan, 2001)
Trujillo v. Williams
465 F.3d 1210 (Tenth Circuit, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Emrit v. United States Patent and Trademark Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emrit-v-united-states-patent-and-trademark-office-mied-2025.