Greene v. United States Postal Service
4:25-cv-00451
E.D. Mo.Apr 14, 2025Background
- Cedric Greene, a highly litigious pro se plaintiff, filed suit against the United States Postal Service (USPS) in the Eastern District of Missouri, alleging issues with mishandled and lost certified mail sent in 2023.
- Plaintiff originally filed similar claims in the U.S. Court of Federal Claims, which dismissed for lack of jurisdiction, a decision later not pursued on appeal.
- Greene has a prolific history of filing similar cases across multiple federal courts, resulting in filing restrictions and monetary sanctions due to abusive litigation.
- The instant complaint was filed in Missouri despite Greene’s California residency and no relevant acts or omissions occurring in Missouri, raising venue concerns.
- The court considered Greene’s repetitive and duplicative lawsuits as evidence of a pattern of vexatious and malicious litigation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction | USPS mishandled mail—should be liable for damages | USPS not subject to claims for lost mail | No jurisdiction; barred by postal exception |
| Venue | Case should be processed in Missouri | No relevant events in Missouri | Venue improper |
| In Forma Pauperis Status | Should be granted due to inability to pay | N/A | Denied |
| Malicious/Frivolous Filing | Prior sanctions unconstitutional | Pattern of vexatious litigation | Action dismissed as malicious |
Key Cases Cited
- Dolan v. United States Postal Serv., 546 U.S. 481 (Supreme Court holds FTCA does not waive sovereign immunity for postal losses)
- Cochran v. Morris, 73 F.3d 1310 (Court may consider litigant’s broader filing history in finding malice)
- Jones ex rel. Jones v. Correctional Medical Servs., Inc., 401 F.3d 950 (Non-attorneys may not litigate on behalf of others in federal court)
- Iannaccone v. Law, 142 F.3d 553 (Pro se status only allows self-representation)
- Lewis v. Lenc–Smith Mfg. Co., 784 F.2d 829 (Unlicensed individuals cannot represent others in court)
