Carter v. Platforms

Background

Justin Carter, representing himself, sued Meta Platforms, Inc. He alleged that Meta wrongly closed his Instagram account for allegedly violating its terms of use. Carter said he used the account for freelance programming work and had more than 9,500 followers. He also alleged that a replacement Instagram account and his Facebook account were suspended for the same alleged violation.

Carter asserted claims for defamation, breach of contract, and intentional interference with prospective economic advantage. He sought an injunction restoring his accounts and $5,000 in damages. The court had granted his application to proceed without paying filing fees.

Jurisdiction and Screening

Because Carter was allowed to proceed without paying filing fees, the court was required to screen his complaint under 28 U.S.C. § 1915(e)(2)(B). The court explained that it must dismiss claims that are frivolous or malicious, fail to state a claim, or seek money from an immune defendant. It also explained that it must dismiss a complaint when no basis for federal jurisdiction appears from the allegations.

The court identified two possible bases for federal jurisdiction. Federal-question jurisdiction requires a claim arising under federal law, the Constitution, or a treaty. Diversity jurisdiction requires all plaintiffs to be citizens of different states from all defendants and at least $75,000 in controversy.

Although Carter identified federal-question jurisdiction in his complaint, the court found that he had not identified a violation of federal law, the Constitution, or a treaty. The court also found that the complaint did not allege enough facts to establish diversity jurisdiction. In addition, Carter requested only $5,000 in damages, while diversity jurisdiction generally requires more than $75,000 in controversy.

Order

The court ordered Carter to show cause—meaning to explain—why the case should not be dismissed for lack of federal jurisdiction. By December 10, 2025, he could either file an amended complaint addressing the identified deficiencies or file a response explaining why the existing complaint was sufficient.

The court vacated the January 21, 2026 case-management conference. It stated that if Carter did not respond by the deadline, the case would be reassigned to a district judge with a recommendation that it be dismissed under 28 U.S.C. § 1915(e)(2)(B). The order itself did not dismiss the case. It also stated that any amended complaint would replace the original complaint and would need to include all facts, claims, and defendants Carter wished to present.