Adams v. Trump, 2:17-cv-11925

Jerome S. Adams, proceeding pro se, sought to proceed in forma pauperis and sued President Donald J. Trump asserting that Trump "took" money awarded to Adams in prior lawsuits and from a movie about his life; he claimed $500,000,000,000 in controversy.
Adams alleged the taking occurred between May and November 2016 and requested return of all money allegedly taken; the complaint contained no factual detail about the underlying lawsuits, awards, or how Trump allegedly took the funds.
The Court granted Adams in forma pauperis status but screened the complaint under 28 U.S.C. § 1915(e)(2)(B).
The Court found the complaint failed to satisfy Federal Rule of Civil Procedure 8(a) and failed to state a claim under Rule 12(b)(6), lacking factual or legal grounds to hold Trump liable.
The Court deemed the allegations frivolous, denied the plaintiff’s request for service by the U.S. Marshal as moot, dismissed the action with prejudice, closed the case, and found any appeal would be frivolous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint states a claim on which relief can be granted	Adams: Trump took money awarded to Adams in prior suits and from a movie; Adams is entitled to return of that money	No substantive defense presented in the record	Dismissed for failure to state a claim under Rule 12(b)(6) — complaint lacks factual and legal allegations connecting Trump to any recoverable wrong
Whether the complaint is frivolous under § 1915(e)(2)(B)	Adams: alleged monetary loss and entitlement to relief	Not applicable	Court held the complaint is frivolous because it lacks an arguable basis in law or fact
Whether the Court should order service by the U.S. Marshal	Adams requested marshal service	Not applicable	Request for service denied as moot because the action was dismissed at screening
Whether an appeal would be taken in good faith under § 1915(a)(3)	Adams did not advance legal basis for appeal	Not applicable	Court found any appeal would be frivolous and not taken in good faith

Neitzke v. Williams, 490 U.S. 319 (explains standard for dismissal of frivolous claims)
McGore v. Wrigglesworth, 114 F.3d 601 (requires screening of in forma pauperis non-prisoner complaints under § 1915(e)(2))
Haines v. Kerner, 404 U.S. 519 (pro se complaints held to less stringent standard)
Coppedge v. United States, 369 U.S. 438 (addresses good-faith standard for appeals under § 1915)
Jones v. Bock, 549 U.S. 199 (discusses procedural aspects overruling aspects of McGore on other grounds)