Woodhouse v. Meta Platforms Inc.

• Court: District Court, District of Columbia
• Decided: July 13, 2023
• Docket: Civil Action No. 2023-1924
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_________________________________________ ) BENJAMIN WOODHOUSE, ) ) Plaintiff, ) ) v. ) Case No. 23-cv-01924 (APM) ) META PLATFORMS INC., et al., ) ) Defendants. ) _________________________________________ )

MEMORANDUM OPINION

Plaintiff Benjamin Woodhouse, proceeding pro se, brings the instant action against

Defendants. 1 For the reasons stated below, the court dismisses the Complaint and this action sua

sponte.

It is well-settled that “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,

wholly insubstantial, [or] obviously frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974)

(cleaned up). A complaint will be dismissed pursuant to Federal Rule of Civil Procedure 12(b)(1)

when it is “‘patently insubstantial,’ presenting no federal question suitable for decision.” Best v.

Kelly, 39 F.3d 328, 330 (D.C. Cir. 1994) (quoting Neitzke v. Williams, 490 U.S. 319, 327 n.6

(1989)). Claims are patently insubstantial if they are “essentially fictitious,” for example,

advancing “bizarre conspiracy theories,” “fantastic government manipulations of [one’s] will or

mind,” or some type of “supernatural intervention.” Id. at 330. In such cases, a district court

may dismiss the case sua sponte. See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008)

1 Defendants are Meta Platforms Inc., Alphabet Inc., Nike Inc., Gibson Dunn & Crutcher Inc., Attorney General Rob Bonta, U.S. Attorney David Harris, Judge Stanley Blumenfeld, Judge Gary Klausner, Judge Christina Snyder, Judge Dean Pregerson, Judge Lawrence Van Dyke, Judge Eric Miller, Judge Mark Bennett, Judge Joanne Osinoff, and Ninth Circuit Clerk Molly Dwyer (each in their official capacity). (quoting Brown v. Dist. Unemployment Comp. Bd., 411 F. Supp. 1001, 1001–02 (D.D.C. 1975)

(noting that “a district court has the power to dismiss a case sua sponte if it is frivolous”)).

Here, Plaintiff’s Complaint rests on the kind of fantastic and delusional claims that warrant

dismissal sua sponte. Specifically, Plaintiff alleges that Defendants operated a “genocide hotel”

in Pismo Beach, CA and held “impromptu death trials” in which “close to 3,000 people . . . have

been murdered.” See Compl., ECF No. 1, at 12, 14. Plaintiff also alleges a “full entourage of

commandos attempted to breach [Plaintiff’s] property and assassinate him from an uninhabited

area adjacent to [Plaintiff’s] property after helicopter insertion,” but “fortunately, [the commandos]

inadvertently incinerated themselves with napalm.” Id. at 20. Moreover, Plaintiff contends that

Defendants “imprison[ed] the Chinese Ambassador to the U.S.” in order to “stem shoe sales to

China, and leverage their coercive behavior against [Plaintiff].” Id. at 23. The court is permitted

to dismiss a complaint containing such allegations. See Neitzke, 490 U.S. at 325; see also Crisafi

v. Holland, 655 F.2d 1305, 1307–08 (D.C. Cir. 1981) (“A court may dismiss as frivolous

complaints . . . postulating events and circumstances of a wholly fanciful kind.”). Accordingly,

upon sua sponte review, this action is dismissed.

A separate final, appealable order accompanies this Memorandum Opinion.

Dated: July 13, 2023 Amit P. Mehta United States District Judge