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Chikhladze v. Tbilisi-Based Organized Group
2:25-cv-02185
D. Kan.
Apr 22, 2025
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Background

  • Simon Chikhladze, proceeding pro se, sued the Kingdom of Denmark, Georgian authorities, Tea Tsulukiani, and others for alleged human rights and immigration violations, including obstruction of justice and conspiracy against rights.
  • Plaintiff's claims stem from Denmark's denial of his asylum application, subsequent extradition from Germany to Denmark, and deportation to Georgia, where he alleges persecution and mistreatment.
  • Chikhladze argued Denmark's actions violated international refugee law and the principle of non-refoulement, and that Tea Tsulukiani, a Georgian official, coordinated efforts to suppress evidence of wrongdoing.
  • The plaintiff requested to proceed in forma pauperis due to lack of income and limited financial means.
  • The District of Kansas court screened the complaint under 28 U.S.C. § 1915(e), considering venue and jurisdiction sua sponte.
  • The court identified that neither defendants nor events had any connection to Kansas and noted plaintiff's history of similar cases dismissed elsewhere for improper venue.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
In Forma Pauperis Plaintiff cannot afford filing fees and meets statutory criteria. N/A Granted; plaintiff may proceed without paying fees.
Venue Harm from federal immigration violations relates to Kansas. No connection to Kansas. Dismissed; no connection to Kansas, so venue improper.
Personal Jurisdiction Claims fall under federal statutes, so Kansas is proper. No facts support jurisdiction. No facts support jurisdiction; cannot be cured.
Claims Under Federal and International Law Defendants violated civil rights and refugee protections. N/A Not reached substantively due to venue dismissal.

Key Cases Cited

  • Neitzke v. Williams, 490 U.S. 319 (1989) (discussing the purpose of screening and dismissal under § 1915 for frivolous actions)
  • Lister v. Dept. of Treas., 408 F.3d 1309 (10th Cir. 2005) (trial court discretion to grant or deny in forma pauperis status)
  • Trujillo v. Williams, 465 F.3d 1210 (10th Cir. 2006) (district court may dismiss for lack of personal jurisdiction and improper venue under § 1915)
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Case Details

Case Name: Chikhladze v. Tbilisi-Based Organized Group
Court Name: District Court, D. Kansas
Date Published: Apr 22, 2025
Docket Number: 2:25-cv-02185
Court Abbreviation: D. Kan.