Johnson v. Zuckerberg
- Martinez-Olguin
- 3:23-cv-03910
- U.S. District Court · Northern District of California
- 3
In Johnson v. Zuckerberg, Judge Martinez-Olguin dismissed Johnson’s amended civil-rights claims as duplicative of a settled class action.
Tyler D. Johnson’s individual civil-rights action was dismissed as duplicative of the related class action; the court also terminated pending motions and closed the case.
What happened
Tyler D. Johnson, who was incarcerated in Missouri and represented himself, filed a civil-rights lawsuit under a federal law allowing claims against state officials. The court previously found that his allegations and request for money appeared to duplicate those in a related class action that had reached a settlement.
The court gave Johnson 28 days to amend his complaint and allege that he had opted out of that settlement. Johnson filed an amended complaint, but it repeated similar allegations and did not say that he had opted out. He also attempted to name multiple plaintiffs even though the court had denied his request to certify a class.
Judge Araceli Martinez-Olguin ruled that the amended complaint did not fix the identified problems. The court dismissed Johnson’s claims as duplicative, directed the Clerk to terminate all pending motions, and closed the file.
The detailed version
- Johnson v. Zuckerberg · No. 3:23-cv-03910
- Martinez-Olguin
- Oct. 28, 2024
Background
Tyler D. Johnson, an inmate in Missouri who represented himself, brought a civil-rights action under 42 U.S.C. § 1983. The court had allowed him to proceed without paying the filing fee. In an earlier screening order, the court found that Johnson’s allegations and request for damages appeared to duplicate the allegations and requested damages in a related class action, Case No. 18-md-2843-VC, concerning data privacy.
The court also found that Johnson appeared to fit the criteria for membership in that class action’s Missouri subclass. The related class action had reached a settlement, and Johnson had not alleged that he opted out. The court directed him to submit any claim for damages to the settlement administrator. It also instructed him that requests for other equitable relief had to be pursued through the class action rather than through a separate individual lawsuit. The court dismissed the original complaint with leave to amend and gave Johnson 28 days to file an amended complaint alleging that he had opted out of the settlement.
Amended Complaint
Johnson filed an amended complaint. The court found that it named similar defendants and made similar allegations to those in the original complaint. Johnson also attempted to name multiple plaintiffs, even though the court had previously denied his motion for class certification. The amended complaint did not allege that Johnson had opted out of the settlement agreement and did not provide further argument addressing whether his claims were related to those in the related class action.
Ruling
The court held that the amended complaint did not cure the pleading deficiencies identified in the earlier order. It therefore ordered that Johnson’s claims be DISMISSED AS DUPLICATIVE. The Clerk was directed to terminate all pending motions and close the file. The opinion does not state that this dismissal was with or without prejudice.
Classification
This is a procedural order because the court dismissed the action as duplicative without deciding the underlying data-privacy claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.