Dunbar v. Zuckerberg

Background

Janis L. Dunbar filed the complaint without a lawyer and asked to proceed without prepaying filing fees. The court had granted that request on March 28, 2025. Dunbar invoked federal-question jurisdiction and sued Mark Zuckerberg, Eduardo Savarin, and Dustin Moskovitz. The opinion describes Zuckerberg as Meta’s chief executive officer and Savarin and Moskovitz as Meta “co-owners.”

Dunbar alleged that Curtis James Jackson/50 stalked and scammed her online, including an alleged $600 loss. She also alleged that Zuckerberg knew about her book, changed Facebook’s name to Meta because of information in the book, and stopped features that Messenger had used. She further alleged stalking, hacking, police surrounding her, and efforts to have her placed in a mental hospital. She sought “a billion” dollars in damages.

Legal standard

For a complaint filed without prepaying fees, the court must dismiss the case if the complaint is frivolous or malicious, fails to state a claim for relief, seeks money from a defendant immune from such relief, or presents claims over which the court lacks subject-matter jurisdiction. A claim is frivolous when it lacks an arguable factual or legal basis. The court must read a self-represented person’s complaint liberally, but the complaint still must provide a short and plain statement showing entitlement to relief.

Court’s reasoning and ruling

The court concluded that Dunbar’s allegations, including the claim that the defendants changed Facebook’s name because of her book, were irrational and not plausible. It found that the allegations did not create a right to relief under any legal theory. The court therefore dismissed the action as frivolous under 28 U.S.C. § 1915(e)(2)(B)(i).

The court stated that amendment would be futile because the defects could not be cured. It declined to grant leave to amend and directed the Clerk of Court to enter judgment. The opinion does not state that the dismissal was with or without prejudice.