Jerus v. Honda Corporation

Background

Janet A. Jerus filed the action without a lawyer and paid the filing fee. She identified federal-question jurisdiction and described her claim as involving civil-rights issues, including “discrimination, socialism, communism, etc.”

The opinion says Jerus appeared to own or have owned a 1995 Honda Civic. She alleged that defendants replaced a new alternator with an old one and switched twelve engine screws, causing the car to break down. She also appeared to allege that she bought a used 2001 Honda Accord from defendants. According to the complaint, a salesperson told her there was an oil leak, she believed the car was guaranteed to operate for three months or 90 days, and she later discovered that the purchase documents described the car as sold “as is.” She alleged that she was locked in an office and forced to sign the purchase agreement, and that the Accord later required substantial repairs. She sought payment of repair bills.

Jerus also made allegations involving kidnapping, sex, extortion, spiritual planes, money laundering, drugging, a mental ward, forgeries, an illegal contract, a forced confession, and other conduct. The opinion describes most of these allegations as disjointed, incomprehensible, irrational, or wholly incredible.

Motion and legal standards

Santa Clara Imported Cars, Inc., doing business as Honda of Stevens Creek, and Joseph Spurrier moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally valid claim. The court explained that a complaint must provide enough specific facts to give defendants fair notice of the claims and must state a claim that is plausible on its face. Because Jerus was representing herself, the court was required to read her allegations liberally, but it still was not required to accept every possible interpretation of unclear allegations.

Court’s analysis

The court held that the complaint failed to provide fair notice because most of its allegations were unclear and did not identify understandable claims or the grounds for relief.

The court also addressed the apparent civil-rights claim under 42 U.S.C. § 1983. That statute provides a remedy for the deprivation of federal rights when the deprivation occurs under color of state law—that is, through government authority or conduct attributable to the government. The court found that the defendants were a private citizen and a private entity. Jerus did not allege that either defendant was a state actor or that their conduct was attributable to a government entity. The court therefore held that the complaint did not plead a viable civil-rights claim.

Disposition

The court granted defendants’ motion to dismiss. It allowed Jerus to file an amended complaint against the original defendants only, no later than August 7, 2020. The opinion does not state that the dismissal was with or without prejudice.