William Frank Perron v. The City of Manhattan, New York
2:24-cv-04039
C.D. Cal.May 21, 2024Background
- On April 4, 2023, former President Donald Trump was arraigned in New York on 34 felony counts related to alleged falsification of business records, linked to efforts to influence the 2016 presidential election.
- On May 15, 2024, William Frank Perron, a California resident and Trump supporter, filed a federal lawsuit in the Central District of California seeking to halt Trump’s ongoing New York criminal trial.
- Perron sought a temporary restraining order and writ of prohibition to immediately enjoin the New York trial until after the 2024 presidential election.
- Perron argued that the New York trial constituted voter suppression by impeding his ability to assess Trump’s candidacy.
- No defendants were present or had been served at the time of the court’s order; the proceeding was reviewed in chambers.
- The district court dismissed the complaint without leave to amend, citing lack of subject matter jurisdiction, standing, personal jurisdiction, improper venue, mandatory abstention, and futility of amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing | Perron claims the trial harms his rights as a voter. | Not addressed by Defendants (not yet served); court analyzed directly. | No standing; harm is indirect and hypothetical. |
| Abstention (Younger) | Sought federal intervention in ongoing state proceedings. | Not addressed by Defendants. | Court must abstain under Younger doctrine. |
| Personal Jurisdiction | New York defendants’ actions impact plaintiff in CA. | Not addressed by Defendants. | No personal jurisdiction over NY defendants. |
| Venue | Sought relief in Central District of California. | Not addressed by Defendants. | Venue improper; only acts in NY alleged. |
Key Cases Cited
- Ballard v. Stanton, 833 F.2d 593 (6th Cir. 1987) (plaintiff lacked standing to seek to enjoin another’s state criminal trial)
- Linda R.S. v. Richard D., 410 U.S. 614 (1973) (nexus required between plaintiff’s injury and challenged action for standing)
- Massachusetts v. Mellon, 262 U.S. 447 (1923) (taxpayer suits require individualized injury, not public concern)
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts abstain from interfering with ongoing state criminal proceedings)