During this past quarter, U.S. Senior District Judge Charles J. Siragusa afforded a pro se plaintiff who alleged a panoply of claims ranging from sexual harassment, retaliatory termination, conspiracy, fraud, money laundering, and sex-trafficking ample opportunities to proceed before dismissing her complaint. In Howland v. Univ. of Rochester, No. 19-CV-6532 CJS, 2020 WL 7337718, at *1 (W.D.N.Y. Dec. 14, 2020), the pro se litigant filed suit against her former university employer and its largest corporate donor alleging that she was wrongfully terminated after expressing concern that both the university and the donor were jointly engaged in a variety of nefarious and illegal activities. In dismissing these "fantastic" allegations, Judge Siragusa made it clear that her case lacked merit and that her status as a pro se litigant did not excuse her suit's deficiencies.

Background

In July 2019, plaintiff filed a complaint containing allegations of sexual harassment and retaliation against her former employer, a private university (university-defendant). Notably, though, she did not allege typical Title VII or Title IX claims. Instead, plaintiff alleged that her male supervisor "sexually harassed" her in order to retaliate against her after she discovered that the university-defendant former employer was involved in an illegal conspiracy with its largest corporate donor (also a defendant in the case and hereinafter referenced as donor-defendant) to commit fraud, money laundering and sex-trafficking. Although not entirely clear, plaintiff appears to have initially attempted to bring claims pursuant to the Racketeer Influenced Organizations (RICO) statute and 18 U.S.C. §371 (conspiracy to commit offense or to defraud United States).