WHIGUM v. BONDI
3:25-cv-00476
N.D. Fla.Apr 17, 2025Background
- Plaintiff Connie Frances Whigum, proceeding pro se, filed a complaint and paid the filing fee in the Northern District of Florida.
- The amended complaint named numerous past and present political figures (including Trump, Obama, Biden, and even King Charles) as defendants.
- The allegations included implausible personal claims, such as familial ties to Thomas Jefferson, Julius Caesar, and Abraham Lincoln, and broad conspiracy theories involving U.S. and U.K. officials, judges, and agencies.
- Whigum has a documented history of repeatedly filing frivolous and abusive lawsuits in this district, all of which were previously dismissed.
- The court previously imposed a screening order on the plaintiff’s filings due to her repeated abuses of the judicial process.
- The magistrate judge reviewed the current complaint, found it to be frivolous, and recommended sua sponte dismissal without leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint states a claim | Whigum claims government conspiracy and personal lineage to historical figures | No valid legal/factual basis | Complaint is patently frivolous |
| Suit against high profile figures | Names multiple political figures and foreign leaders as co-conspirators | Defendants challenge merits | Dismissed for lack of plausibility |
| Leave to amend | No argument for leave to amend | N/A | Leave to amend not warranted |
| Abuse of judicial process | Plaintiff continues to file repetitive, frivolous lawsuits | Prior filing bar and past abuse | Action dismissed as abusive filing |
Key Cases Cited
- Bilal v. Driver, 251 F.3d 1346 (11th Cir. 2001) (defining a frivolous legal claim as one lacking any arguable basis in law or fact)
- Denton v. Hernandez, 504 U.S. 25 (1992) (court may dismiss factually fantastic, delusional, or incredible claims as frivolous)