Wilkes v. San Mateo County Transit District

Background

Michael Troy Wilkes, proceeding without a lawyer, filed a complaint against San Mateo County Transit District (SAMTRANS), Bay Area Rapid Transit, Caltrain, San Mateo Police Department, California Department of Motor Vehicles, San Mateo Superior Court, San Mateo Event Center, United Airlines, Delta Airlines, AirBnB, Inc., and U.S. Bank. He alleged violations of Titles I, II, III, and V of the Americans with Disabilities Act, denial of due process, and housing discrimination under the Fair Housing Act.

Wilkes’s primary dispute concerned his use of “prosthetic inline skates as a mobility aid.” He alleged that he has severe pelvic injuries and pain-induced cardiovascular events and that defendants denied him access because of his inline skates.

The court previously granted Wilkes permission to proceed without paying the filing fee, subject to mandatory screening under 28 U.S.C. § 1915(e)(2). After that screening, the court found that the complaint failed to state any claims, dismissed it with leave to amend, and directed steps for service. Wilkes did not file an amended complaint, and the defendants had not been served.

Wilkes later filed motions and requests concerning a service deadline, access to federal courthouses, accommodations for his mobility aid, reconsideration of the denial of an extension, subpoenas, and related issues. The court had told him that he could provide defendants’ addresses by email or mail and did not need to appear physically at a courthouse to comply. The court also directed him to submit broader courthouse-accommodation requests through a specified administrative email address rather than in this case.

Legal standard

Under 28 U.S.C. § 1915(e)(2), the court must dismiss a case filed by a person proceeding without paying the filing fee if it is frivolous, fails to state a claim for relief, or seeks money from a defendant protected from such relief. A claim is frivolous when it lacks an arguable basis in law or fact. The court also explained that a case may be dismissed as frivolous when the plaintiff has not established standing or federal subject-matter jurisdiction. The court applied a standard similar to the standard for dismissing a complaint for failure to state a claim and recognized that complaints filed without a lawyer are read liberally.

Court’s reasoning

The court gave two principal reasons for dismissal. First, it found that Wilkes had not filed an amended complaint correcting the deficiencies previously identified and that his later filings did not establish subject-matter jurisdiction. The court also found that some requests—such as demands for accommodations at federal courthouses and requests involving federal agency staff—went beyond the case properly before it. The court concluded that the scattered allegations did not give defendants fair notice of what Wilkes was claiming and that his requests for subpoenas lacked a sufficient legal or factual basis.

Second, the court found that Wilkes had repeatedly ignored court orders and local rules. In particular, it found that he filed motions to reconsider without first obtaining the required permission and continued to repeat requests concerning courthouse access and service after the court had explained that physical courthouse access was unnecessary for providing addresses or participating in the case.

Disposition

The court dismissed the case as frivolous under 28 U.S.C. § 1915(e)(2) with prejudice. It denied leave to amend as futile because Wilkes had been warned about the deficiencies and had not corrected them. The court also denied all pending motions, vacated existing deadlines, directed the Clerk of Court to terminate the case, and resolved docket entries 16, 17, and 19.