Major v. Social Security Administration
- Beth Freeman
- 5:24-cv-03199
- U.S. District Court · Northern District of California
- 3
In Major v. Social Security Administration, Judge Freeman dismissed the Google claim for failure to state a claim and dismissed the Social Security challenge without prejudice.
Matthew Benjamin Major’s claims against Google.com and the Social Security Administration were dismissed; the Social Security claim may be pursued in a new action, while the Google claim was dismissed for failure to state a claim.
What happened
In Major v. Social Security Administration, Matthew Benjamin Major, a state prisoner proceeding without a lawyer, sued the Social Security Administration and Google.com under a civil-rights law. He challenged the denial of Social Security benefits and sought back pay, and he also made allegations about Google’s website and requested that YouTube restore his videos.
The court screened the complaint as required in prisoner cases. It ruled that Google and YouTube are private businesses, not government actors subject to that civil-rights law, and that the allegations did not adequately describe a constitutional violation. The court also explained that a challenge to the Social Security decision could not proceed under that civil-rights law.
Judge Freeman dismissed the claim against Google.com for failure to state a claim. The court dismissed the Social Security claim without prejudice, allowing Major to pursue the benefits challenge in a new action using the appropriate form and paying the required fees.
The detailed version
- Major v. Social Security Administration · No. 5:24-cv-03199
- Beth Freeman
- Oct. 1, 2024
Background
Matthew Benjamin Major, identified as a state prisoner housed at the Maguire Correctional Facility, filed this action without a lawyer under 42 U.S.C. § 1983 against the Social Security Administration and “Google.com.” He alleged that his last application for Social Security benefits, filed in February 2022, was denied and sought “back pay” for Social Security benefits since 2017. He also alleged that a Google internet website caused his name and family address to be associated with harmful conduct and sought to have YouTube restore his past videos.
Screening standard
Because Major was a prisoner seeking relief from governmental entities or employees, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court had to dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also stated that a § 1983 claim requires an alleged violation of a constitutional or federal-law right by a person acting under color of state law, meaning through authority connected to state government.
Google claim
The court held that the claim against Google, or YouTube, was not cognizable under § 1983 because those business entities are not state actors. The court also found that the allegations were insufficient to establish a constitutional-rights violation because they were largely nonsensical and conclusory. It concluded that the deficiencies could not be corrected through amendment and dismissed the claim against Google.com for failure to state a claim for which relief could be granted.
Social Security claim
The court ruled that Major could not use a § 1983 action to challenge the Social Security Administration’s decision. It stated that he could pursue an appeal of the denial of Social Security benefits against the Administration in a new action using the appropriate court form and paying the appropriate fees. That claim was dismissed without prejudice.
Disposition
The claim against Google.com was dismissed for failure to state a claim for which relief could be granted. The Social Security claim was dismissed without prejudice. The clerk was directed to provide Major with a copy of the appropriate complaint form, terminate pending motions, and close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.