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Court Denies Pauper Status, Dismisses Trafficking Claims

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Filed March 10th, 2026
Detected March 24th, 2026
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Summary

The U.S. District Court for the District of Massachusetts denied a plaintiff's application to proceed in forma pauperis and dismissed her claims of human trafficking and terrorism. The court found the complaint lacked specificity and failed to establish jurisdiction.

What changed

The U.S. District Court for the District of Massachusetts, in a Memorandum and Order dated March 10, 2026, denied the plaintiff's motion to proceed in forma pauperis and dismissed her complaint. The plaintiff, representing herself, brought claims of human trafficking and terrorism against various defendants, including state and federal entities. The court noted the complaint's lack of specificity, particularly the statement that facts were "unknown," and the vague nature of the requested relief.

This decision means the plaintiff's case, as filed, will not proceed in federal court. The dismissal is based on the inadequacy of the complaint and the inability to establish jurisdiction. While the plaintiff is representing herself, this outcome highlights the importance of clear factual allegations and specific legal claims when initiating litigation. No compliance actions are required for regulated entities as this is a specific court ruling on a private litigant's filing.

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March 10, 2026 Get Citation Alerts Download PDF Add Note

Angela Dawn Perez Dowling v. The People of State of Massachusetts, et al.

District Court, D. Massachusetts

Trial Court Document

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

ANGELA DAWN PEREZ DOWLING,

Plaintiff,

                                   Civil Action No. 25-30150-MGM     
      v.                                                             

THE PEOPLE OF STATE OF

MASSACHUSETTS, et al.,

 Defendants.                                                         

                MEMORANDUM AND ORDER                                 
                      March 10, 2026                                 

MASTROIANNI, U.S.D.J.

                     I.   INTRODUCTION                               
Angela Dawn Perez Dowling (“Plaintiff”), who resides in Arizona and is representing herself, 

filed a complaint naming as defendants the People of the State of Massachusetts, the United States
Border Patrol, the People of the State of California, the People of Tax ID: 452647441, and the People
of the SEC (Security and Exchange Commission).” (Compl., Dkt. 1 at ¶ I(B). Plaintiff states that her
claim concerns “Human Traffic[k]ing” and “Terrorism.” (Id. at ¶¶ II(A), III). For the statement of
facts, Plaintiff alleges that to the ‘[b]est of [her] knowledge [the facts are] ‘unknown.’” (Id. at ¶ III). In
the relief section of the complaint, Plaintiff writes “’In Question’ ‘Review’ unknown Review Best of
your knowledge.” (Id. at ¶ IV).

Plaintiff has also filed an Application to Proceed in District Court Without Prepaying Fees or
Costs (docketed as a motion for leave to proceed in forma pauperis and a motion to amend. (Dkt. Nos.
2, 4). For the reasons set forth below, the court will DENY the motion for leave to proceed in forma
pauperis, DENY the motion to amend, and DISMISS this action.

II. MOTION FOR LEAVE TO PROCEED

Under the federal in forma pauperis statute, a court “may authorize the commencement . . . of
any suit . . . without prepayment of fees or security therefor, by a person who submits an affidavit
that includes a statement of all assets such [person] possesses [showing] that the person is unable to
pay such fees or give security therefor.” 28 U.S.C. § 1915 (a)(1). One does not have to be “absolutely
destitute” to proceed in forma pauperis. Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948). Rather, the litigant must show she cannot pay the filing fee “and still be able to provide [her]self
and dependents with the necessities of life.” Id. Leave to proceed in forma pauperis is a privilege, not
a right. See, e.g., Young v. Bowser, 843 Fed. App'x 341, 342 (D.C. Cir. 2021) (per curiam); Daker v. Jackson, 942 F.3d 1252, 1257 (11th Cir. 2019) (per curiam); Bryant v. United States, 618 Fed. App’x 683, 685
(Fed. Cir. 2015) (per curiam).

In the Application, which was signed under penalty of perjury, Plaintiff represents that, in the
past year she has received income from self-employment and food stamps, and that she is owed child
support. However, Plaintiff does not indicate the amount she received and what she expects to receive
in the future, although the directions to the Application require the litigant to provide this information.
In addition, she did not indicate the amount of money she has in a checking or savings account (or in
cash). In response to three of the questions in the Application, Plaintiff responded “unknown.” In
failing to clearly answer each question, Plaintiff has failed to provide a complete statement of her

assets. The court cannot determine whether Plaintiff can pay the filing fee and still be able to afford
the necessities of life for herself and any dependents. Because of this, the court will deny the motion
for leave to proceed in forma pauperis.

III. REVIEW OF THE COMPLAINT

The federal courts possess certain “‘inherent powers,’ not conferred by rule or statute, ‘to
manage their own affairs so as to achieve the orderly and expeditious disposition of cases.’” Goodyear
Tire & Rubber Co. v. Haeger, 581 U.S. 101, 107 (2017) (quoting Link v. Wabash R.R. Co., 370 U.S. 626,
630-31
(1962)). Those powers include the power to dismiss frivolous or malicious actions, regardless
of the status of the filing fee. See Mallard v. United States Dist. Ct., 490 U.S. 296, 307-308 (1989); Brockton
Sav. Bank. v. Peat, Marwick, Mitchell & Co., 771 F.2d 5, 11 n.5 (1st Cir. 1985). As used in this context,
“frivolous” does not refer to the subjective intent of a plaintiff. Axcella Building Realty Trust v. Thompson,
No. 23-40151-DHH, 2024 WL 474539, at n. 2 (D. Mass. Jan. 25, 2024). “Rather, in legal parlance, a

complaint is ‘frivolous’ if it ‘lacks an arguable basis either in law or in fact.’” Id. (quoting Neitzke v.
Williams, 490 U.S. 319, 325 (1989)). In conducting this review, the court liberally construes Plaintiff’s
complaint because she is proceeding pro se. See Erikson v. Pardus, 551 U.S. 89, 94 (2007).
Rule 8(a) of the Federal Rules of Civil Procedure requires that the complaint contain “a short
and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2).
This statement must “‘give the defendant fair notice of what the . . . claim is and the grounds upon
which it rests.’” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (alteration in original) (quoting
Conley v. Gibson, 355 U.S. 41, 47 (1957)). It must afford the defendants a “meaningful opportunity to
mount a defense,” Díaz-Rivera v. Rivera-Rodríguez, 377 F.3d 119, 123 (1st Cir. 2004) (quoting Rodríguez
v. Doral Mortgage Corp., 57 F.3d 1168, 1172 (1st Cir. 1995)).

Plaintiff’s complaint does not comply with Rule 8(a). The complaint states that the claim is
based in federal law, but Plaintiff has not identified any federal statute or provision of the Constitution

that provides a basis for her claim, or any other legal basis for relief. While the complaint refers to
human trafficking and terrorism, Plaintiff never connects these vague allegations to any of the
defendants. In fact, other than being named as defendants in the matter, none of the defendants are
mentioned in the complaint at all.

Plaintiff has been a frequent litigant in this district, filing unsuccessful lawsuits against similarly
named defendants. See e.g. Plaintiff v. The People of Dallas Police Department, et al., No. 25-12648-MRD
(dismissed Dec. 2, 2025); Plaintiff v. The People of the Court, 25-13262-JEK (dismissed Dec. 4, 2025). An
on-line search of the federal Judiciary’s Public Access to Court Electronic Records (PACER) service
reveals that Plaintiff has filed no less than seventy-nine (79) pro se civil actions spanning nine federal
courts. See https://pacer.uscourts.gov (last visited March 6, 2026). In 2024, the District of Arizona
entered an Order finding Plaintiff to be a vexatious litigant and enjoined her from filing any new
actions in that court without obtaining leave of the court by filing a motion for leave to file with copies

of the pleadings and including an affidavit certifying that the claim or claims presented are new and
have not been raised by Plaintiff in a federal court and that to the best of Plaintiff’s knowledge, the
claim or claims presented are neither factually nor legally frivolous and are not taken in bad faith.
Plaintiff v. Arizona Vehicle Theft Task Force, 2024 WL 4894734, *4 (D. Ariz. Nov. 26, 2024).
As to Plaintiff’s motion to amend, she has not attached a proposed amended complaint or
indicated the substance of her proposed amendment. (Dkt. No. 4). In light of the nature of the claims
asserted, the court finds that amendment would be futile. Garayalde-Rijos v. Municipality of Carolina, 747
F.3d 15, 23
(1st Cir. 2014) (explaining that sua sponte dismissal is appropriate only when it is crystal
clear that the plaintiff cannot prevail and that amending the complaint would be futile).
IV. CONCLUSION

For the reasons set forth above,                                     
  1. Plaintiff’s motion for leave to proceed in forma pauperis (Dkt. No. 2) is DENIED.
  2. This action is DISMISSED pursuant to the court’s inherent authority. It is So Ordered.
    /s/ Mark G. Mastroianni_______
    MARK G. MASTROIANNI
    United States District Judge

Named provisions

INTRODUCTION

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
D. Massachusetts
Filed
March 10th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
Civil Action No. 25-30150-MGM
Docket
3:25-cv-30150

Who this affects

Applies to
Immigration detainees Legal professionals
Industry sector
5411 Legal Services 9211 Government & Public Administration
Activity scope
Litigation
Geographic scope
Massachusetts US-MA

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Immigration Human Trafficking

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