Williams v. Patel

• Court: District Court, District of Columbia
• Decided: February 10, 2026
• Docket: Civil Action No. 2025-4280
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ALFREDA DENISE WILLIAMS,

Plaintiff,

v. Civil Action No. 25 - 4280 (UNA)

KASH PATEL,

Defendant.

MEMORANDUM OPINION

Before the court is Plaintiff Alfreda Denis Williams’s complaint, ECF No. 1, and motion

to proceed in forma pauperis, ECF No. 2. The court will grant the application to proceed in forma

pauperis and dismiss the complaint as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

“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)). A complaint that lacks “an arguable basis either in

law or in fact” is frivolous, Neitzke v. Williams, 490 U.S. 319, 325 (1989), and the 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). 28 U.S.C. § 1915 requires a court to dismiss a case “at any time if the court determines

that . . . the action or appeal . . . is frivolous.” Consequently, the court is obligated to dismiss a complaint as frivolous when, as here, “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).

Ms. Williams claims to be a “Federal Special Agent” named “America D. Trump,” and she

is “requesting” that the court remove Kash Patel from his role as Director of the Federal Bureau

of Investigation. ECF No. 1, at 6. She alleges, among other things, that Director Patel has “close

involvement” in a “Plot to Rape or Kill a[] White American Leader/Republican/Navy Veteran/Law

Enforcement Officer Elite Federal Special Agent AI/Royalty” (this appears to be Ms. Williams,

herself), as well as plots to inject her with cancer and computer chips and have her stalked. Id. at

7-8.

The court concludes that Ms. Williams’s claim lacks an arguable basis in law or fact

because her core assertions are wholly irrational. See Neitzke, 490 U.S. at 325. The court will

accordingly grant her motion to proceed in forma pauperis, ECF No. 2, and dismiss her complaint,

ECF No. 1, without prejudice.

LOREN L. ALIKHAN United States District Judge Date: February 9, 2026