NYLJ Eastern District Roundup
Case Dismissed for Frivolous Allegations and Lack of Subject Matter Jurisdiction
Posted: January 9, 2026 / Written by: Samuel L. Butt, John Moore / Category NYLJ Eastern District Roundup
Case Dismissed for Frivolous Allegations and Lack of Subject Matter Jurisdiction
This column reports on several significant representative decisions from the U.S. District Court for the Eastern District of New York. In Emrit v. Burnett, 25 CV 2873 (EDNY, Nov. 27, 2025), Judge Pamela K. Chen dismissed pro se plaintiff’s complaint against, among others, Erin Burnett and Volodymyr Zelensky, sua sponte, for lack of subject matter jurisdiction and because it was frivolous.