From Judge Kenneth Karas (S.D.N.Y.) Friday in Center for Judicial Accountability, Inc. v. Legislative Correspondents' Ass'n :

On October 8, 2025, Plaintiff Elena Sassower ..., proceeding pro se, along with the Center for Judicial Accountability, Inc. ... brought this Action, alleging the 34 Defendant media outlets and journalism-related entities ... conspired to commit "journalistic fraud," "institutional reckless disregard for truth," and "defraud[ed] purchasers, contributors, [and] taxpayers" in violation of the First Amendment to the United States Constitution.

No, said the court; an excerpt:

[CJA] claims Defendants' "violation of First Amendment responsibilities and journalistic codes by the press, including most of the [D]efendants herein, has meant that all of [CJA]'s hard, painstaking work, spanning more than three decades, has brought no corruption-eradicating changes[ ] when even a modicum of press adherence to such responsibilities and codes ... could have brought sweeping[,] corruption-eradicating changes," but this alleged injury is too remote and speculative to constitute an injury in fact....

CJA also claims that "[t]he near total press suppression of any report of [its] work, other than in minimizing, deprecating terms, deprived it of any public profile and appreciation [ ] and all the benefits flowing therefrom[,]" but "the constitutional right of free speech has never been thought to embrace a right to require a journalist or any other citizen to listen to a person's views, let alone a right to require a publisher to publish those views in his newspaper." Accordingly, because CJA has no legally cognizable right to favorable press coverage of its work, it cannot assert an injury-in-fact on this basis....

Plaintiffs [also] claim to bring this Action on behalf of the People of the State of New York who

have been kept 'clueless' by their 'free press' as to how they have been betrayed by their elected and appointed constitutional officers in their three government branches whose flagrant violations of their oaths of office, the state Constitution, laws, and rules, steal their money, ... and enact and enable the enactment of policies, without legislative due process and by fraud, including as relates to elections ....

However, ... Sassower's pro se status precludes her from litigating on behalf of anyone except herself. Additionally, ... Plaintiffs cannot rely on harm suffered by the general public to establish standing because the injury in fact must be particularized to the individuals bringing a case.

Further, as explained above, Plaintiffs do not have a legally enforceable right—under the First Amendment or any other authority—to force Defendants to report on the topics of their choice, so they cannot claim injury to themselves or the general public on that basis.

And an excerpt as to Sassower's more personalized claim:

First, Plaintiffs lack a legally cognizable "injury in fact" as required to establish standing. In detailing her alleged injury, Sassower claims that "the corruption of New York's judiciary ... and the complicity of the press, including many [of the Defendants], destroyed the lives and professional careers of her ... parents," which, in turn, "destroy[ed] and derail[ed] [Sassower's] own life and career[ ] beginning when she was a child[,] and she is now 69."

However, any injury suffered by Sassower's parents does not give her standing to bring this Action because an alleged constitutional violation "is entirely personal to the direct victim of the alleged constitutional tort, and therefore 'no cause of action [based on it] may lie ... for ... consequent collateral injuries allegedly suffered personally by the victim's family members.'" Without providing details as to how Defendants' conduct "destroy[ed] and derail[ed]" her "life and career[,]" Sassower has not pled sufficient facts to plausibly allege she suffered a concrete and particularized injury-in-fact.

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