Goddard v. JPMorgan Chase Bank

Background

Pro se plaintiff Thomas Joseph Goddard filed his original complaint against JPMorgan Chase Bank, N.A. on February 2, 2026, and filed a First Amended Complaint on February 13, 2026. Simultaneously with the original complaint, Goddard filed an application to proceed in forma pauperis (IFP) — a statutory mechanism under 28 U.S.C. § 1915 that allows indigent litigants to file civil cases without prepaying court filing fees. He later filed a second IFP application on April 10, 2026. Goddard also filed multiple requests for an exemption from fees charged by PACER (the Electronic Public Access to Court Electronic Records system), including two additional motions filed April 9 and 10, 2026.

The opinion does not describe the underlying claims against JPMorgan Chase Bank, N.A., as the court addressed only the threshold IFP and PACER fee exemption questions in this order.

Plaintiff's Financial Circumstances

According to his financial affidavits, Goddard is not currently employed and reported no income from any source over the past 12 months. His original IFP application stated he received CalFresh public food assistance ($298/month) and Medi-Cal benefits, but his more recent application clarified that his State Disability Insurance (SDI) benefits were exhausted by approximately March 2026, and he has received $0.00 in income since then. He owns no home, no car, and no cash. He is involuntarily confined at the Department of State Hospitals – Napa (referred to in the opinion as DHS Napa) and has no access to financial accounts of any kind. He has no personal expenses outside confinement but accumulated approximately $19,000 in credit card debt for survival necessities prior to confinement. His PACER account has been suspended since approximately March 2026.

Legal Standards Applied

In Forma Pauperis (IFP)

Under 28 U.S.C. § 1915(a)(1), a federal court must authorize commencement of a civil action without prepayment of fees when a plaintiff submits an affidavit listing all assets and showing inability to pay. The statute does not define what level of indigency suffices; that determination rests in the court's discretion. See Williams v. Cnty. of Ventura, 443 F. App'x 232, 233 (9th Cir. 2011). An affidavit is sufficient if it shows the applicant cannot pay court costs and still afford the necessities of life. Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015). A party need not be absolutely destitute to qualify, but must demonstrate that paying fees would constitute a serious hardship rather than a minor inconvenience. Id. at 1234.

PACER Fee Exemption

Courts may grant a PACER fee exemption upon a showing that an exemption is necessary to avoid unreasonable burdens and to promote public access to information. Carter v. USDA, No. 19-cv-03096-NC, 2020 WL 14025995, at *2 (N.D. Cal. Jan. 6, 2020).

Rulings

IFP Applications (Dkts. 2, 20)

The court found Goddard's affidavits sufficient — no income, no assets, no financial account access, and involuntary confinement — to establish that paying the filing fee would pose a substantial economic hardship. The court granted both IFP applications.

PACER Fee Exemption (Dkts. 5, 19, 20)

Based on the same financial record establishing indigency, the court granted the PACER fee exemption requests. The exemption is limited to fees incurred accessing documents filed in this case, expires when the case is closed, and may be revoked at any time at the court's discretion. Any outstanding PACER balance (account number 8394159) related to this case was waived. Goddard is prohibited from selling or transferring data obtained using the exemption.

Mandatory Screening

Because IFP status was granted, 28 U.S.C. § 1915(e)(2)(B) requires the court to screen the operative First Amended Complaint before the case proceeds. The court stated it will issue a separate order on whether the complaint satisfies the mandatory screening requirements. Until that separate order issues, the Clerk of Court was directed not to issue a summons and the U.S. Marshals were directed not to serve process.

Disposition Summary

- Dkts. 2, 20 (IFP applications): Granted - Dkts. 5, 19, 20 (PACER fee exemption requests): Granted (subject to stated limitations) - Mandatory § 1915(e)(2)(B) screening of the First Amended Complaint: deferred to a separate order - Summons and service of process: withheld pending screening