Greene v. Ratcliff

• Court: District Court, District of Columbia
• Decided: June 16, 2026
• Docket: Civil Action No. 2026-0991
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LAUREN GREENE, et al., ) ) Plaintiffs, ) ) Civil Action No. 1:26-cv-00991 (UNA) v. ) ) ) W. BURNS, et al., ) ) ) Defendants. )

MEMORANDUM OPINION

This matter is currently before the Court on consideration of Plaintiff’s Complaint, ECF

No. 1, and Application for Leave to Proceed in forma pauperis (“IFP”), ECF No. 2. Upon review,

the Court grants Plaintiff’s IFP Application, and for the reasons explained below, it dismisses this

matter without prejudice.

At the outset, the Court notes that Plaintiff, who is proceeding pro se, attempts to bring this

case on behalf of an entity, “Citizens Against Forensic Psychiatry.” However, a non-individual

cannot proceed under the IFP statute, 28 U.S.C. § 1915(a)(1); the Supreme Court has interpreted

that provision as applicable “only to individuals” or “natural persons,” not “artificial entities,”

Rowland v. Cal. Men’s Colony, 506 U.S. 194, 201–07 (1993), nor can a pro se plaintiff proceed,

IFP or otherwise, on behalf of an entity, if as here, that plaintiff is not licensed counsel, see 28

U.S.C. § 1654; Greater Southeast Cmty. Hosp. Found., Inc. v. Potter, 586 F.3d 1, 4 (D.C. Cir.

2009) (citing Rowland, 506 U.S. at 201–02); see also Franklin v. Vilsack, No. 11–0206 (D.D.C.

Apr. 15, 2011) (denying IFP status to plaintiff in his capacity as an officer of a non-profit

corporation, because the non-profit, as an artificial entity, cannot proceed IFP). The Complaint itself is difficult to understand. Plaintiff sues the President of the United

States, CIA officials, a judge, named and unnamed law enforcement officers, and the D.C.

Department of Behavioral Health. She has also filed a Motion to Amend, ECF No. 4, proposing

adding yet more random defendants, but providing absolutely no basis for such request. The

Complaint’s allegations are presented in run-on paragraphs consisting of stream-of-consciousness

narrations of anecdotes that span Plaintiff’s life, and include bare recitations of federal laws.

Plaintiff alleges that she has been a victim of “federal conspiracies,” primarily orchestrated by the

CIA, that have resulted in human trafficking, real and intellectual property theft, corrupt abuse,

false charges and arrests, misdiagnosis of mental health conditions, hacking, and that she faced

unlawful court proceedings. She also alleges that her food and coffee were poisoned by the

military in Philadelphia and that she was prevented from participating in the U.N. General

Assembly. She demands equitable relief and $1 million in damages.

Applicable here, a “complaint must contain sufficient factual matter, accepted as true, to

‘state a claim to relief that is plausible on its face,’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)

(quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)), and a complaint that lacks “an

arguable basis either in law or in fact” is frivolous. Neitzke v. Williams, 490 U.S. 319, 325 (1989).

Moreover, a federal court cannot exercise subject matter jurisdiction over a frivolous complaint.

Hagans v. Lavine, 415 U.S. 528, 536–37 (1974) (“Over the years this Court has repeatedly held

that the 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.’”) (quoting

Newburyport Water Co. v. Newburyport, 193 U.S. 561, 579 (1904))); Tooley v. Napolitano, 586

F.3d 1006, 1010 (D.C. Cir. 2009) (examining cases dismissed “for patent insubstantiality,”

including where the plaintiff allegedly “was subjected to a campaign of surveillance and harassment deriving from uncertain origins”). A court may dismiss a complaint as frivolous “when

the facts alleged rise to the level of the irrational or the wholly incredible,” Denton v. Hernandez,

504 U.S. 25, 33 (1992), or “postulat[e] events and circumstances of a wholly fanciful kind,” Crisafi

v. Holland, 655 F.2d 1305, 1307–08 (D.C. Cir. 1981). The instant Complaint falls squarely into

this category.

Accordingly, this matter is dismissed without prejudice. See 28 U.S.C. § 1915(e)(2)(B)(i).

Plaintiff’s Motion to Amend, ECF No. 4, is denied, and her Motion to Expedite, ECF No. 3, is

denied as moot. A separate Order accompanies this Memorandum Opinion.

Date: June 16, 2026

Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge