The defendant, Springer Nature, brought a motion under Rule 21 to strike the statement of claim filed by the self-represented plaintiff, Ahmad Mohammad, without leave to amend, on the basis that it disclosed no reasonable cause of action.
The plaintiff sought a court order requiring the defendant, a leading academic journal, to retract a 1997 paper he believed was founded on fraudulent research, which caused him "extreme annoyance" and a "mental tort," leading to his expulsion from his Ph.D. program.
The court dismissed the motion, finding that the plaintiff's complaint did not disclose a recognized cause of action, as academic controversies are not justiciable in this context, and his "annoyance" or "mental tort" did not constitute a legally recognized injury in tort law.
Furthermore, the alleged injury was too remote and not foreseeable under the objective "ordinary person" standard for mental harm.
Costs were awarded to the defendant.
