The United States District Court for the District of Columbia has dismissed a lawsuit brought by Aiyoba Sara’mamy Akansa, who claimed to be an Indigenous descendant of the Arawak people. The lawsuit targeted various entities, including the Department of Commerce, the State of Illinois, and a federal judge, alleging racial misclassification, violations of international law, and other grievances.
Plaintiff’s Claims and the Defendants
Akansa, proceeding without a lawyer, filed the lawsuit based on several legal grounds, including the Alien Tort Statute, the First, Fifth, and Fourteenth Amendments to the U.S. Constitution, and international law. She named a long list of defendants, including:
* The United States Department of Commerce
* Secretary of Commerce Howard W. Lutnick
* The United States Census Bureau (collectively, the “Federal Defendants”)
* The State of Illinois
* Governor J.B. Pritzker
* The Illinois Department of Public Health and its director, Sameer Vohra (collectively, the “State Defendants”)
* Judge Charles Ashley Royal, a senior district court judge
* Putnam County, Georgia
* The Putnam County Sheriff’s Department
* Putnam County Sheriff Howard R. Sills
Akansa’s central argument was that the federal and state defendants misclassified her race in government records, severing her from her tribal identity and associated federal rights. She also claimed Judge Royal acted improperly in previous land-related court decisions. She sought a range of remedies, including a declaration that Judge Royal’s rulings were void, correction of her racial and tribal records, and financial compensation.
The Court’s Decision: Lack of Jurisdiction
The court, presided over by Judge Tanya S. Chutkan, granted motions to dismiss filed by the Federal Defendants and the Illinois Department of Public Health. The court’s decision was primarily based on a lack of subject matter jurisdiction, meaning the court determined it did not have the authority to hear the case.
Lack of Concrete Injury and Standing
One of the key reasons for dismissal was Akansa’s failure to demonstrate a “concrete injury,” a necessary element for establishing standing to sue in federal court. The court found that Akansa’s claim of harm from racial misclassification, without any evidence of the information being disclosed to third parties, was not sufficient to establish a concrete injury. The court noted that federal law provides extensive privacy protections for census data.
Sovereign Immunity
The court also cited sovereign immunity as a barrier to the lawsuit. Sovereign immunity protects the federal government, its agencies, and its employees acting in their official capacities from being sued. The court found that Akansa had not established any waiver of sovereign immunity that would allow her to sue the federal and state defendants for money damages. The court also noted that the Alien Tort Statute, cited by the plaintiff, does not waive sovereign immunity.
Furthermore, the court found that Akansa failed to exhaust administrative remedies under the Federal Tort Claims Act (FTCA), which is a prerequisite for suing the United States.
Judge Royal’s Actions and Declaratory Relief
Regarding Judge Royal, the court stated it lacked jurisdiction to review the decisions of other federal courts. The court explained that challenging the legality of decisions made by a judge in their judicial capacity should be addressed through an appeal to an appellate court, not a new lawsuit in a different district court. The court also noted that judges are protected by judicial immunity for actions taken in their official capacity.
Dismissal of Other Claims
Finally, the court dismissed claims that it deemed “attenuated and unsubstantial,” including allegations of “crimes against humanity,” “racial apartheid,” and “identity erasure.” The court reasoned that even if it had reached the merits of these claims, Akansa had not provided sufficient factual details to support them.
The Ruling’s Impact
The court’s decision effectively ends Akansa’s lawsuit against the Federal Defendants, the State Defendants, and Judge Royal. The court’s opinion highlights the importance of establishing standing and overcoming jurisdictional hurdles in federal court. The court’s decision underscores the high bar for suing government entities and officials, particularly when claims involve alleged violations of international law or constitutional rights. The court’s reasoning underscores the importance of concrete harm and the limitations of suing for mere misclassification without further consequences.