In this case, this is what the court is saying make it frivolous: "failure to state a claim upon which relief could be granted." So even if Obama is proven ineligible, the court can say there's no way for the court to provide relief for the claim ... as in the courts don't think it's in their jurisdiction to declare a president ineligible, remove the president or nullify the elction results because the Constitution doesn't specifically give them these powers. Nevermind that the court gives itself plenty of other powers not defined in the Constitution or elsewhere. This is their fallback excuse for staying out of the issue.
I understand that's the court's cop out. And it's true, the court couldn't order the removal of the President. The most the court could do provide fact finding and a referal to congress.
But I don't think that warrants sanctions, either.