Griffin v. Facebook

Background

Casimir Griffin filed the action without a lawyer while being held at the Orange County Jail. The court had previously allowed him to proceed without prepaying the filing fee. He sued Facebook, Instagram, Snap Chat, PayPal, Draft Kings, Messenger, Meta Mask, Cash App, Extra Card, One Bank, TD Bank, and 150 unidentified parties.

Griffin invoked federal-question jurisdiction and attempted to assert federal constitutional claims under 42 U.S.C. § 1983. He alleged that events occurred on the internet, social media, cloud services, phone applications, in Newburgh, New York, and at the Orange County Jail between 2019 and 2025. His allegations included claims that his phone and accounts were compromised, money was taken from financial accounts, communications were diverted, and he suffered injuries and other losses. He sought $550 million per minute in damages.

Reasons for dismissal

The court explained that a complaint filed by a person proceeding without prepaying fees must be dismissed if it is frivolous, fails to state a claim, seeks money from an immune defendant, or if the court lacks subject-matter jurisdiction. The court also noted that pleadings filed without a lawyer are read generously, but they still must provide enough factual detail to state a plausible claim.

First, the court held that it lacked federal-question jurisdiction. Section 1983 requires facts showing that each defendant acted under state authority. Griffin sued only private parties and alleged no facts showing that they worked for a state or other government body or otherwise acted as state actors. The court also found no plausible federal claim, constitutional or otherwise, against the defendants.

The court separately held that Griffin had not established diversity-of-citizenship jurisdiction. He did not state his pre-incarceration domicile, and he did not allege the citizenship of the corporate defendants. In particular, he did not allege where each corporation was incorporated. The court also found that, despite Griffin’s demand for $550 million per minute, his allegations did not suggest that any potentially available state-law claims were worth more than the $75,000 jurisdictional minimum.

Second, the court found that many allegations were factually frivolous. It identified as unsupported Griffin’s allegations that he was a constant target of witchcraft, that jail staff took his blood for witchcraft, and that an alleged chemical called “Techno-99” allowed people to look into a person’s nervous system and communicate with them radioactively. The court characterized these allegations as conclusory, irrational, and lacking plausible factual support.

Disposition

The court dismissed the complaint for lack of subject-matter jurisdiction and as frivolous under the statute governing complaints filed by people unable to prepay fees. It denied leave to amend because the court concluded that the identified defects could not be cured by amendment. The court directed the Clerk of Court to enter judgment.