Comment by Sean Munger
The world according to Teri Smith Tyler is a frightful place. According to the complaint that she filed in the United States District Court for the Southern District of New York in December 1992, Ms. Tyler was the victim of one of the most insidious and fiendish conspiracies ever devised by the mind of man: the Iron Mountain Plan. Perpetuated by a vast array of defendants including former President Jimmy Carter, then-President-Elect Bill Clinton, IBM Corporation, and NASA, as well as others, the Iron Mountain Plan sought to enslave millions of African-American women into “death-hunting” thrill-kill rackets, breed young black girls as human pets, and dominate the globe by causing weather disasters and earthquakes. As a political dissident opposed to this horrific scheme, Tyler had been subjected to strafing attacks by low-flying planes, electronic surveillance, and psychological harassment utilizing noise and social ostrification.
This was only the tip of the iceberg. Through a form of telepathic communication called “proteus,” Tyler learned the grisly secrets of the Iron Mountain Plan in great detail. For example, former President Carter was the biological father of Bill Clinton. Clinton allegedly masterminded the World Trade Center bombing so as to provoke another war with Iraq. This attack was a sequel to the 1991 Persian Gulf War, whose actual purpose was (according to proteus communications with former Secretary of Defense Richard Cheney) to restock the nation's sexual slavery camps with Persians [sic] who provided more thrilling murder and gang-rape experiences than the black girls usually used for this purpose. This “American holocaust” had already resulted in the deaths of ten million black women, whose carcasses were processed into meat and leather products, apparently to the financial benefit of death-hunting industry barons such as Texas entrepreneur H. Ross Perot. Tyler sought $5.6 billion in damages for herself, plus an end to the “holocaust” and an investigation into the death of every black woman born after 1940.
Though her allegations were quite broad, Tyler did attempt to offer proof of her claims that the Iron Mountain Plan existed. Among other things, she produced a pamphlet advertising pornographic films featuring young men of Mediterranean and Latin American descent. She presumed these men to be victims of the sexual slavery industry who may have been part of the group of 40,000 Iraqi soldiers captured by American forces in the Persian Gulf War specifically for use in these pornography “rackets.” Tyler might also have had independent corroboration to support her claims if her foes had not intervened. For example, deposed Panamanian dictator Manuel Noriega could have joined her lawsuit because of his knowledge of American military raids in Central America to capture children and turn them into sex slaves, but Noriega was forcibly prevented from having contact with Tyler. Furthermore, former Indian Prime Minister Rajiv Gandhi could have offered his own sordid tale of sexual captivity, but, of course, Gandhi was killed in a terrorist attack in 1991.
It was quite clear that Tyler was doing everything she could to derail the Iron Mountain Plan. In addition to her lawsuit against Carter, Clinton, and the other defendants, she also attempted in three separate actions to enjoin the inauguration of Clinton as President of the United States, the swearing-in of Louis Freeh as FBI Director, and the World Trade Center bombing trial. Armed with at least some familiarity with judicial procedures, she paid filing fees and effected service of process on Clinton and other federal defendants. Though she did not complete service upon them, Tyler's claim troubled defendants IBM and the Bank of Commerce and Credit International enough for their lawyers to actually appear in court to make motions to dismiss, which were eventually granted on September 29, 1993. Presidents Carter and Clinton, though allegedly eyeballs-deep in the Iron Mountain conspiracy, moved to dismiss the case.
Judge Haight ruled that if Tyler had proceeded to court under the federal in forma pauperis statute, 28 U.S.C. § 1915, her claim would have been dismissable as frivolous. However, because she had paid filing fees, the dismissal for frivolity was instead appropriate under Federal Rule of Civil Procedure 12(b)(6), sua sponte. Though its allegations are more colorful than most, the kind of claims asserted in Tyler v. Carter are disturbingly common in federal courts. The Supreme Court of the United States has observed, “[C]laims describing fantastic or delusional scenarios [are] claims with which federal district judges are all too familiar.” Courts' dockets are frequently peppered with bizarre lawsuits filed by pro se plaintiffs, frequently suing government officials from local to federal levels, often weaving intricate schemes of persecution, surveillance, conspiracy, and evil. Though these claims often provide law clerks, judges, and lawyers with moments of levity in an otherwise dour work day, they illustrate the colorful tip of a problematic iceberg: the perennial dilemma of what to do with claims that really don't belong in federal courts. The federal machinery for allowing in forma pauperis claims contains a mechanism (under recent statutory amendments, apparently applicable to all plaintiffs regardless of technical in forma pauperis status) by which “frivolous” claims can be removed from the docket before they cause an inordinate amount of trouble. However, it is the thesis of this Comment that such a mechanism must be applied with care. Claims such as Teri Smith Tyler's are indisputably a waste of judicial resources, but the amorphous standards used to dismiss such cases are not as well-tailored to the subcategory of delusional claims as they could be. This Comment will posit the viewpoint that, under current standards for pro se cases under 28 U.S.C. § 1915(e)(2), the desire to rid overburdened court dockets of delusional claims may inadvertently eliminate the occasional meritorious case whose factual scenario could be misclassified as “delusional.” Fortunately, there is federal jurisprudence that presents an analysis that would eliminate or significantly reduce this risk, small though it is.
This Comment will first examine the nature and history of delusional claims, their relationship to “frivolous” claims, and the history of judicial and statutory responses to them. Then, the Comment will examine the history of courts' responses to delusional and frivolous claims, culminating in the current formulation of § 1915(e)(2). Finally, the appropriateness of courts' usual forms of analysis will be tested by the use of two hypotheticals that illustrate the rare possibility of a meritorious claim that could easily be mistaken as delusional. Over the course of this analysis, the reader is respectfully asked to keep an open mind.
About the Author
Sean Munger. J.D. Candidate, Tulane Law School, 1998.
Citation
72 Tul. L. Rev. 1809 (1998)