Aiyahnna Johnson and Lesgetit Networks LLC v. Alameda County Social Services

Background

Aiyahnna Johnson filed the complaint and an application to proceed in forma pauperis, meaning to start the case without paying the filing fee. The complaint names Aiyahnna Johnson and Lesgetit Networks LLC as plaintiffs and Alameda County Social Services Agency, the City of Los Angeles Department of Public Social Services, Rubrik, Inc., 35 Ventures LLC, Kevin Durant, and Rich Kleiman as defendants.

The complaint alleges that public agencies wrongfully denied or interfered with Johnson’s CalFresh, CalWORKs, and Medi-Cal benefits; accessed or shared her confidential social-services records and personal data; and coordinated with private parties to monitor or prevent her employment. It also asserts constitutional and statutory claims and several state-law claims, including emotional-distress, privacy, confidentiality, unjust-enrichment, economic-interference, and harassment claims. The plaintiffs seek $60,000,000 in economic damages, punitive damages, injunctive relief, and attorney’s fees and costs.

Application to Proceed Without Paying the Filing Fee

The court found that Johnson submitted information showing she could not afford the costs of the action. But a corporation may not proceed without paying the filing fee. Because Lesgetit Networks LLC was also listed as a plaintiff, the court deferred ruling on the application. If the company remains a plaintiff, the order requires it to pay the $405 filing fee.

Screening of the Complaint

The court screened the complaint under 28 U.S.C. § 1915(e), which requires dismissal of a fee-waiver complaint before service if it is frivolous or malicious, fails to state a claim, or seeks money from an immune defendant. The court found that the complaint fails to state a claim under that standard, but it did not dismiss the case in this order.

Representation of the Company

A corporation may appear in federal court only through a licensed lawyer. The order states that nothing before the court indicates Johnson is an attorney and that, based on the current record, she cannot represent Lesgetit Networks LLC. The company must either file a notice of appearance through counsel or be omitted as a named plaintiff in the amended complaint. The court warned that failure to obtain counsel for the company could result in dismissal of its claims.

Rule 8 and Identification of Claims

Federal Rule of Civil Procedure 8 requires a complaint to provide a short and plain statement showing why the plaintiff is entitled to relief. The court found that the complaint asserted multiple claims against multiple defendants without explaining how each defendant was liable for each claim. Its blanket allegations that all defendants assisted one another did not give the defendants adequate notice of the allegations against them.

The amended complaint must identify the specific laws or rights allegedly violated; connect each defendant to particular wrongdoing, including dates, people involved, and actions taken; explain the harm; and state the relief sought. The court also required the amended pleading to include all facts, claims, and defendants rather than incorporate the original complaint by reference.

Claims Against Private Parties

The court explained that constitutional claims generally require conduct fairly attributable to the government. For claims under 42 U.S.C. § 1983, a plaintiff must plausibly allege that a private party’s conduct constituted state action. Purely private conduct, even if wrongful, is not actionable under § 1983. If the plaintiffs pursue constitutional claims against private defendants, the amended complaint must plausibly allege state action.

Order

The court deferred ruling on the application to proceed without paying the filing fee and found that the complaint fails to state a claim under 28 U.S.C. § 1915(e). It ordered the plaintiffs to file a first amended complaint by April 9, 2026. If Lesgetit Networks LLC remains a plaintiff, counsel must file a notice of appearance and pay the $405 filing fee by April 6, 2026. The court warned that failing to cure the identified deficiencies could lead to dismissal.