From Casetext: Smarter Legal Research

Brown v. Burmania

United States District Court, District of Columbia
Jun 21, 2022
Civil Action 22-1708 (UNA) (D.D.C. Jun. 21, 2022)

Opinion

Civil Action 22-1708 (UNA)

06-21-2022

LEWIS ROSS BROWN, Plaintiff, v. TESSA L. BURMANIA et al., Defendants.


MEMORANDUM OPINION

DABNEY L. FRIEDRICH, UNITED STATES DISTRICT JUDGE

Lewis Ross Brown, a former employee of the Environmental Protection Agency, alleges that defendants “blacklisted [him] from employment within the Federal Government after [he] was removed for exercising [his] right to file an EEO Complaint and to report [defendants'] misconduct . . . to the Agency OIG” and others. Compl. at 3, Dkt. 1. He purports to bring this action under the Universal Declaration of Human Rights. See id. His claim fails because the Declaration does not provide a private right of action. See Sosa v. Alvarez-Machain, 542 U.S. 692, 734 (2004) (“[T]he Declaration does not of its own force impose obligations as a matter of international law.”); Vizi v. Outback Steakhouse, 672 Fed.Appx. 168, 171 n.1 (3d Cir. 2016) (per curiam) (finding that “Universal Declaration of Human Rights . . . is a nonbinding declaration that provides no private rights of action”); Konar v. Illinois, 327 Fed.Appx. 638, 640 (7th Cir. 2009) (finding that appellant “cannot state a claim under the Universal Declaration of Human Rights or the Vienna Declaration because both are non-binding declarations that provide no private rights of action”); Perry v. Frederick, No. 22-CV-1973, 2022 WL 1810713, at *1 n.3 (E.D. Pa. June 2, 2022) (recognizing Third Circuit's ruling in United States v. Chatman, 351 Fed.Appx. 740, 741 (3d Cir. 2009), that “the Universal Declaration of Human Rights is a nonbinding declaration that provides no private rights of action”).

The Court will grant plaintiff's application to proceed in forma pauperis and, for the reasons stated above, dismiss the complaint and this civil action. An Order is issued separately.


Summaries of

Brown v. Burmania

United States District Court, District of Columbia
Jun 21, 2022
Civil Action 22-1708 (UNA) (D.D.C. Jun. 21, 2022)
Case details for

Brown v. Burmania

Case Details

Full title:LEWIS ROSS BROWN, Plaintiff, v. TESSA L. BURMANIA et al., Defendants.

Court:United States District Court, District of Columbia

Date published: Jun 21, 2022

Citations

Civil Action 22-1708 (UNA) (D.D.C. Jun. 21, 2022)