Satish Emrit et al v. Obama et al

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
RONALD SATISH EMRIT,
Plaintiff,
v.
BARACK HUSSEIN OBAMA, et al.,
Defendants.
No. 26-cv-11216-JDH
ORDER ON MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS,
ORDER FOR REASSIGNMENT, AND REPORT AND RECOMMENDATION
HEDGES, M.J.
Pro se plaintiff Ronald Satish Emrit has filed a civil complaint and an application to
proceed in district court without prepaying fees or costs (which the Court will refer to as a
motion for leave to proceed in forma pauperis). For the reasons stated below, I allow the motion
for leave to proceed in forma pauperis, order that this action be reassigned to a District Judge,
and recommend to the District Judge that this action be dismissed as frivolous.1
1 As a preliminary matter, I note that the Court retains jurisdiction over this case notwithstanding
Mr. Emrit’s most recent filing of a notice of appeal. Docket No. 4. In general, “the filing of a
notice of appeal divests the district court of jurisdiction over matters related to the appeal.”
Acevedo-Barcia v. Vera-Monroig, 368 F.3d 49, 58 (1st Cir. 2004). However, “the district court
can proceed, notwithstanding the filing of an appeal, if the notice of appeal is defective in some
substantial and easily discernible way (if, for example, it is based on an unappealable order).”
Rivera-Torres v. Ortiz Velez, 341 F.3d 86, 96 (1st Cir. 2003) (quoting United States v. Brooks,
145 F.3d 446, 456 (1st Cir. 1998)). In this case, there is no question that Mr. Emrit’s notice of
appeal is patently defective because the Court has issued no orders in this matter. The Court
therefore retains complete jurisdiction over the action.
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I. 	Motion for Leave to Proceed in Forma Pauperis
Upon review of Mr. Emrit’s motion for leave to proceed in forma pauperis, I conclude
that he has adequately shown that he is eligible for a waiver of the filing fee. Accordingly, the
motion is GRANTED.
II. 	Order for Reassignment
Pursuant to a Standing Order of this Court, a case may be randomly assigned, at the time
of filing, to a Magistrate Judge. However, absent the parties’ consent to the final assignment of
this case to a Magistrate Judge, a Magistrate Judge is without jurisdiction to involuntarily
dismiss an action. See 28 U.S.C. § 636(b)(1)(A).
As set forth below, I conclude that this action is subject to dismissal. Because the parties
have not consented to the final assignment of this case to a Magistrate Judge, I order that this
action be reassigned to a District Judge.
III. 	Report and Recommendation
Because Mr. Emrit is proceeding in forma pauperis, his complaint is subject to a
preliminary review, and the Court may dismiss any claim that is frivolous or fails to state a claim
upon which relief may be granted. See 28 U.S.C. § 1915(e)(2)(B)(i), (ii).
A. 	Mr. Emrit’s Claims
Mr. Emrit asserts that he “is bringing forth this complaint for 500 billion dollars for the
commission of the torts of public nuisance, and tortious interference.” Docket No. 1 at 1. He
names as defendants former president Barack Obama, Michelle Obama, Former President Joe
Biden, Jill Biden, Hunter Biden, Supreme Court Justice Ketanji Brown Jackson, former Prince
Andrew of the Windsors, and British Prime Minister Keir Starmer.
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Mr. Emrit alleges that he is “an independent presidential candidate who is a supporter of
President Donald J. Trump, Vice President JD Vance, and Secretary of State Marco Rubio.”
Docket No. 1 ¶ 22. Mr. Emrit represents that, in 2016, he ran for president as “Presidential
Candidate # P60005535.” Id. ¶ 24. Mr. Emrit claims that, during that candidacy, he was
interviewed by Craig Tomashoff, whom he identifies as “the senior producer of the Kelly
Clarkson Show.” Id. According to Mr. Emrit, he and Mr. Tomashoff visited the United States
District Court for the District of Neveda in Las Vegas “where the plaintiff showed him a
document uploaded to PACER on a public computer indicating that Florida Secretary of State
Ken Detzner and Kristi Reid-Bronson from his office at the RA Gray Building in Tallahassee
sent the plaintiff a letter indicating that he would be placed on the ballot in Florida for the 2016
election.” Id. ¶ 26.
The complaint asserts four counts. In Count One, titled “Defamation (Libel and
Slander),” Mr. Emrit brings a claim against President Obama for “defaming the current president
by appearing in interviews and podcasts when most former presidents try to stay out of the
spotlight based on a sense of professional courtesy.” Id. ¶ 27. In Count Two, Mr. Emrit brings a
claim for “Public Nuisance” against President Obama for “trying to remain relevant to the
modern-day political conversation.” Id. ¶ 28. Count Three is a claim for “Industrial Espionage,”
in which Mr. Emrit claims that “companies which feature President … Obama … on their
podcasts or through interviews are committing the tort of industrial espionage.” Id. ¶ 29. In
Count Four, Mr. Emrit brings a claim for “Tortious Interference with Business
Relations/Contracts,” alleging that “companies which feature President …Obama … on their
channel’s interviews and/or podcasts are committing the tortious interference with business
relations/contacts under the Federal Tort Claims Act (FTCA).” Id. ¶ 30.
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In his prayer for relief, Mr. Emrit seeks $500,000,000,000 in damages “through joint and
several liability whereby the defendants would presumably seek contribution and indemnity from
each other through the filing of cross-claims.” Id. at 6. Mr. Emrit also seeks an order enjoining
the defendants “from advertising to the plaintiff on Cable TV broadcasts” and a declaratory
judgment that “advertising with artificial intelligence (AI) and algorithms to spy on consumers
for purposes of increasing the company’s stock price . . . is an Antitrust violation perhaps
involving the misdemeanors of trespass, stalking, harassment, and maybe voyeurism. . . .” Id. at
6-7.
B. 	Discussion
A complaint is frivolous “where it lacks an arguable basis either in law or in fact.”
Neitzke v. Williams, 490 U.S. 319, 325 (1989). A claim that is based on an “indisputably
meritless legal theory” lacks an arguable basis in law. Id. at 327.
Here, Mr. Emrit’s complaint is frivolous because it lacks an arguable basis in law and in
fact. All the claims against President Obama are based on “indisputably meritless” legal theories
because the alleged conduct by President Obama (or companies broadcasting his interviews and
podcasts) does not constitute defamation, public nuisance, industrial espionage, tortious
interference with business relations/contracts, or any other tort. Any claims against the other
defendants lack an arguable basis in law and in fact, as Mr. Emrit does not make any factual
allegations concerning these defendants.
IV. 	Conclusion
In accordance with the foregoing:
1. 	The motion for leave to proceed in forma pauperis is GRANTED.
2. 	The Clerk shall reassign the case to a District Judge.
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3. 	I RECOMMEND to the District Judge that this action be dismissed as frivolous.2
SO ORDERED.
Dated: April 9, 2026
/s/ Jessica D. Hedges
United States Magistrate Judge
2 The parties are advised that under the provisions of Federal Rule Civil Procedure 72(b), any
party who objects to these findings and recommendations must file a written objection with the
Clerk of this Court within fourteen days of service of this Report and Recommendation. The
written objection must specifically identify the portion of the proposed findings or
recommendations to which objection is made and the basis for such objection. The parties are
further advised that failure to comply with this rule shall preclude further appellate review by the
Court of Appeals of the District Court order entered pursuant to this Report and
Recommendation. See Santos-Santos v. Torres-Centeno, 842 F.3d 163, 168 (1st Cir. 2016); see
also Keating v. Sec’y of Health & Human Servs., 848 F.2d 271, 275 (1st Cir.1988). A party may
respond to another party’s objections within fourteen (14) days after being served with a copy
thereof. See Fed. R. Civ. P. 72(b).
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