Singh v. Jonas

Background

Gurpreet Singh, proceeding without a lawyer, initially filed a complaint asserting numerous claims under federal and California law. The court allowed him to proceed without prepaying the filing fee. In an earlier screening order, the court dismissed the complaint with leave to amend and directed Singh to specify what each defendant allegedly did and why those actions violated each federal claim.

Singh then filed a first amended complaint naming more than 30 defendants and listing 31 causes of action. The opinion states that the remaining defendants were alleged to be citizens and residents of India. Singh challenged what he described as the unauthorized use of his Instagram account, “gurpreetsingh23065.” He alleged that the defendants impersonated him online, copied and used his content, used it in movie productions and promotional materials, restricted his social interactions, conducted surveillance, harmed his reputation, and caused emotional, reputational, and financial injuries. He sought $800,000,000,000 in compensatory damages.

Screening standard

Because Singh was allowed to proceed without prepaying the filing fee, 28 U.S.C. § 1915(e)(2)(B) required the court to dismiss the action if it was frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also applied Federal Rule of Civil Procedure 8, which requires a short and plain statement showing entitlement to relief. A complaint must include enough factual matter to make a claim plausible; labels, conclusions, and a formulaic list of legal elements are not enough. The court noted that filings by people without lawyers must be read liberally.

Court’s analysis

Singh alleged that the court had both diversity jurisdiction and federal-question jurisdiction. His 31 listed causes of action included defamation, privacy violations, intentional infliction of emotional distress, copyright infringement, cyberbullying, interference with contract, unjust enrichment, false advertising, misrepresentation, conspiracy, unfair competition, alleged civil-rights violations, stalking, harassment, negligent infliction of emotional distress, trespass to chattels, surveillance, interference with prospective economic advantage, right of publicity, anti-cyberharassment violations, consumer-protection violations, misappropriation of likeness, false endorsement, conversion, interference with relationships, age discrimination, and digital-rights violations.

The court found that Singh still had not alleged sufficient facts to support any of these claims. In particular, he did not identify what any individual defendant had done, specify what unauthorized use each defendant allegedly made of his Instagram account, or explain how that conduct resulted in a violation of each asserted cause of action. The court concluded that Singh had not cured the deficiencies identified in the first screening order.

Disposition

The court DISMISSED Singh’s amended complaint without leave to amend. The opinion expressly states that the dismissal is without prejudice.

Effect of the order

The order ended the amended complaint at the screening stage, but because the dismissal was without prejudice, the opinion did not state that the claims were barred from being brought again. The opinion does not decide the factual truth of Singh’s allegations or the merits of the underlying disputes.