Willis v. Bush, 3:21-cv-00263

Pro se plaintiff Lynell Willis filed suit naming former First Lady Laura Bush as sole defendant and sought in forma pauperis status, which the court granted.
Willis alleged long-ago sexual-assault-related misconduct involving a Hardin County judge and vaguely implicated Laura Bush as a passenger in a vehicle; allegations were incoherent and legally unspecific.
The complaint invoked federal-question jurisdiction in a nonstandard fashion and sought broad, nontraditional relief tied to symbolic references to U.S. flag stars and closures of governmental offices.
The court reviewed the complaint under 28 U.S.C. § 1915(e)(2) and applicable precedents for frivolous and jurisdictionally deficient filings.
The court dismissed the action as frivolous and for lack of subject-matter jurisdiction and warned Willis that repeated frivolous filings could result in sanctions, including prefiling restrictions.
The opinion notes Willis’s extensive filing history: 35 civil actions since 2019, 21 reviewed with each dismissed, and 14 dismissed as frivolous; the court issued a warning about future filings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Willis stated a viable federal claim against Laura Bush	Willis alleged a connection to an alleged 1991 sexual assault and implicated Bush as a passenger, asserting violations tied to symbolic flag references	Bush did not file a substantive defense in this proceeding	Court: allegations are frivolous and lack an arguable legal or factual basis; claim dismissed
Whether complaint must be dismissed under 28 U.S.C. § 1915(e)(2) for frivolousness	Willis sought IFP and proceeded with the complaint	No opposing argument; court applied § 1915(e)(2) screening sua sponte	Court: dismissal under § 1915(e)(2)(B) is warranted (frivolous/meritless)
Whether the court has subject-matter jurisdiction	Willis invoked federal-question jurisdiction via noncoherent assertions	No substantive jurisdictional defense presented by defendant	Court: allegations are totally implausible/insubstantial; dismissal for lack of subject-matter jurisdiction under Apple v. Glenn/Hagans
Whether sanctions or prefiling restrictions are appropriate for future filings	Willis continued filing multiple cases despite prior dismissals	No defendant position; court considered Willis’s litigation history	Court: issued a warning and explained it may impose sanctions including prefiling restrictions if frivolous filing continues

McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997) (standards for screening IFP prisoner/plaintiff complaints)
Jones v. Bock, 549 U.S. 199 (2007) (addresses procedural aspects of prisoner civil-rights litigation; cited as overruling McGore on other grounds)
Neitzke v. Williams, 490 U.S. 319 (1989) (defines frivolousness standard for in forma pauperis dismissals)
Apple v. Glenn, 183 F.3d 477 (6th Cir. 1999) (district court may dismiss for lack of subject-matter jurisdiction when claims are utterly frivolous)
Hagans v. Lavine, 415 U.S. 528 (1974) (discusses limits of federal-question jurisdiction for insubstantial claims)
Chambers v. Nasco, Inc., 501 U.S. 32 (1991) (recognizes inherent power of courts to sanction abusive litigation)
Ortman v. Thomas, 99 F.3d 807 (6th Cir. 1996) (addressing limitations and appropriateness of prefiling restrictions)