Watkins v. X Corp.

Background

Jevon Watkins filed the case without an attorney and applied to proceed in forma pauperis, meaning without paying the court filing fee. The complaint names X Corp. and Elon Musk as defendants. Watkins alleged that he paid for advertising for his music and business, but the advertising did not provide everything promised and his social-media account was frozen. He asserted claims under the First and Fifth Amendments and sought restoration of his account or approximately $1,200.

Fee Application and Prior Cases

The court found Watkins’s fee application inconsistent and potentially not credible. He indicated that he was employed but described himself as inactive at Nordstrom, did not provide wage information, and marked many income, asset, and expense fields as not applicable. He stated that he owned or was buying a home and owned a 2021 Cadillac XT5, but did not provide the home’s value, cash amount, or vehicle payment. The court ordered him to explain his finances, including how he meets basic needs and affords the vehicle if he has no income or assets.

Watkins also checked a box indicating that this case did not raise claims presented in other lawsuits, but listed three courts without providing the requested case names and numbers. The court identified two other cases involving him and noted that an earlier court had determined he was a prisoner under the federal filing-fee statute because he was incarcerated at a state forensic psychiatric hospital in Pennsylvania. The court ordered Watkins to clarify whether he is currently a prisoner and to identify all other civil cases he has filed by name, case number, and court.

Problems Identified in the Complaint

The court explained that it would have to screen the complaint if it granted permission to proceed without paying the fee. It stated that the complaint might be dismissed as frivolous or for failure to state a legally sufficient claim. The court also explained that federal courts have limited authority to hear cases and that Watkins had invoked only federal-question jurisdiction.

The court identified several defects:

- Watkins did not identify the federal law or right involved, even though he checked the federal-question jurisdiction box. - His allegations appeared to describe a basic contract dispute, and he did not explain why the First or Fifth Amendments were violated. - The First and Fifth Amendments generally do not apply to private parties. The court stated that Watkins had not alleged that X Corp. or Musk acted for or together with the government. - Watkins had not shown that his direct constitutional claims for damages fit within a recognized legal framework, and he did not identify a statute authorizing those claims. The court also stated that he had not alleged facts supporting a claim under the civil-rights statute for conduct under state law. - His contract allegations did not state basic facts, such as whether the defendants were parties to a contract, how the contract was formed, what the parties promised to do, or how the defendants breached it.

Order

The court ordered Watkins to show cause why his application to proceed without paying the filing fee should not be denied and why his complaint should not be dismissed as frivolous or for failure to state a claim. The order did not itself deny the fee application or dismiss the complaint. Within three weeks of the order, Watkins must file a declaration addressing his finances, a declaration addressing his prisoner status and other civil cases, and either an amended complaint correcting the identified defects or a response explaining why the existing complaint should proceed.

The court stated that any amended complaint must use the same case number, include all claims and defendants Watkins wishes to pursue, and replace the original complaint. It warned that failing to respond could result in dismissal for failure to prosecute and failure to comply with a court order. The court also continued the case-management conference to November 20, 2025, and required a case-management statement by November 13, 2025.