Rogers v. Musk

Background

Joshua Rogers filed the complaint without a lawyer, asserting a breach-of-contract claim against Elon Musk. Rogers was allowed to proceed without paying filing fees under the court’s fee-waiver process. The complaint stated: “I don’t know how or when to collect the said money that is attached too this complaint. It feels like a donation but a person with brain damage I have no clue how this goes. Breach of contact.” Rogers sought $50 million for “quality of life” injuries.

The complaint did not identify the basis for federal jurisdiction. The court noted that Rogers provided no factual allegations supporting his claim and no indication of the legal basis for it.

Screening Standard

Because Rogers was proceeding without paying filing fees, the court was required to dismiss the complaint, or any part of it, if it was frivolous or malicious, failed to state a claim on which relief could be granted, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that pleadings filed without a lawyer are read liberally, but they must still comply with Rule 8 of the Federal Rules of Civil Procedure.

Rule 8 requires a short and plain statement showing that the plaintiff is entitled to relief. The court explained that a complaint must include enough factual detail to make liability plausible and must give each defendant fair notice of the claim and the grounds for it.

Court’s Analysis

The court found that Rogers’s “barebones complaint” did not provide factual allegations supporting the $50 million claim against Musk. It did not give Musk fair notice of the claims or the grounds on which they rested. It also did not identify the legal basis of the claims or explain why the federal court had jurisdiction.

Disposition

The court dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). Judge Louis L. Stanton declined to grant Rogers permission to amend because the court concluded that the defects could not be cured by amendment. The court directed the clerk to enter judgment dismissing the case.

The court also stated that an earlier warning remained in effect. That warning concerned the possibility that Rogers could be required to explain why he should not be barred from filing future complaints without paying filing fees in that court unless he first obtained permission. The opinion states that Rogers had filed more than eleven cases without a lawyer in that district during 2024 and 2025.