Richardson v. U.S. / State of California

Background

Stephan Wayne Richardson filed a complaint and an application to proceed without prepaying the filing fee. He represented himself. The complaint stated, “A statement of damages due to company corruption,” listed sums that appeared to be categories of damages, and requested payment by check or money order within 30 days. It appeared to name “U.S. / State of California” as defendants.

Court’s analysis

The court granted Richardson’s application because his financial affidavit satisfied the economic eligibility requirement for proceeding without prepaying fees. The court explained that granting this status does not prevent later screening of the complaint under 28 U.S.C. § 1915(e). That screening statute requires the court to dismiss certain complaints, including those that fail to state a claim for relief.

The court found that the complaint did not state a claim because it did not identify any legal claims, explain who allegedly owed Richardson money, or explain why. The court also found that the complaint did not show federal-question jurisdiction because it presented no federal question on its face. It did not establish diversity jurisdiction because Richardson did not allege his citizenship, and the court stated that the United States and California are not citizens for diversity-jurisdiction purposes.

Ruling and next steps

The court granted the application to proceed without prepaying the filing fee and found that the complaint failed to state a claim under 28 U.S.C. § 1915(e). It ordered Richardson to file a first amended complaint addressing the identified deficiencies by November 26, 2024. The order did not dismiss the action at that point; it stated that, if Richardson did not file a timely amended complaint, the court would recommend dismissal. The court also vacated the November 6, 2024 case-management conference and said it would be reset later. Chief Magistrate Judge Donna M. Ryu signed the order.