## Facts

- Two incarcerated plaintiffs filed a handwritten, two-page document seeking a temporary restraining order and preliminary injunction against a recording artist and a technology company.
- The filing asserted that the plaintiffs originated the concept for an album titled *1989* and that the artist stole it.
- The filing further alleged implausible misconduct by the artist, including theft of phones and credit cards to purchase concert tickets and demands to restrain the artist from singing lyrics that offended the plaintiffs.
- The filing asserted that the plaintiffs “created” the iPhone in 1989 and included additional bizarre claims involving surveillance and physical harassment by the corporate defendant and the artist.
- Plaintiffs neither paid the civil filing and administrative fees nor submitted motions to proceed in forma pauperis with certified prisoner trust-account statements.

## Issues

1. Whether the action could proceed when prisoner-plaintiffs neither paid the required fees nor filed compliant in forma pauperis motions with certified trust-account statements as required by statute.
2. Whether the court could dismiss, at the outset, allegations that were facially irrational and failed to state any plausible federal claim.
3. Whether extraordinary injunctive relief could be granted in the absence of a plausible underlying claim and credible, non-speculative harm.

## Decision

- The court denied the requested temporary restraining order and preliminary injunction.
- The court ordered the action dismissed due to noncompliance with filing-fee/IFP requirements and because the allegations were “fantastic” and “delusional” and did not state a cognizable claim.
- The court required compliance with statutory fee/IFP prerequisites and the presentation of a coherent, non-frivolous claim as a condition to avoiding dismissal.

## Legal Principles

- A civil action requires payment of statutory fees unless the plaintiff is granted in forma pauperis status; prisoner IFP requests must include a certified trust-account statement for the preceding six months.
- Federal courts may dismiss sua sponte complaints that are frivolous, delusional, or wholly implausible, particularly in threshold screening of prisoner filings.
- Injunctive relief requires a plausible legal claim and a factual showing of real, imminent harm; courts will not issue injunctions based on fanciful allegations or incoherent pleadings.

## Conclusion

The court refused emergency injunctive relief and terminated the case at the outset because the prisoner-plaintiffs did not satisfy statutory fee/IFP filing prerequisites and because the complaint’s allegations were facially implausible and failed to state any cognizable basis for relief.


Darrow v. Swift, 2015 WL 4498057 (D. Mass. 2015)