Shallow v. United States

CourtDistrict Court, District of Columbia
DecidedJune 16, 2026
DocketCivil Action No. 2026-1786
StatusPublished

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

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Shallow v. United States, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SEAN SHALLOW, ) ) Plaintiff, ) ) Civil Action No. 1:26-cv-01786 (UNA) v. ) ) ) UNITED STATES OF AMERICA, ) ) ) Defendant. )

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.

Plaintiff, who purports to be a “DEA Group Leader” and Chief of the United Nations, sues

the United States. The allegations are difficult to understand, presented in run-on paragraphs with

stream-of-consciousness styled anecdotes, spanning decades, presented as evidence of multiple

conspiracies orchestrated against him by his mother, the federal government, and others, with the

intent to, inter alia, murder him, impersonate him, attack him, steal his property, falsely arrest him,

“usurp” him, and engage in other “wicked evil things.”

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).

A separate Order accompanies this Memorandum Opinion.

Date: June 16, 2026

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

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Related

Newburyport Water Co. v. Newburyport
193 U.S. 561 (Supreme Court, 1904)
Hagans v. Lavine
415 U.S. 528 (Supreme Court, 1974)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Tooley v. Napolitano
556 F.3d 836 (D.C. Circuit, 2009)
Salvatore G. Crisafi v. George E. Holland
655 F.2d 1305 (D.C. Circuit, 1981)

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Shallow v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shallow-v-united-states-dcd-2026.