Wilson v. Mount Diablo Unified School District/Special Education Local Plan Area

Background

Michael Geary Wilson filed a complaint and an application to proceed without paying the filing fee. The court found, based on the application, that Wilson lacked funds to pay the fee and granted the application.

The complaint contained 198 pages of text, 27 claims for relief, and 122 defendants. The defendants included a school district, local governments, a California superior court, a superior court judge, local government officials, police officers, and private law firms and attorneys.

Why the Complaint Was Dismissed

Because Wilson was proceeding without paying the filing fee, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2). Screening requires dismissal if the complaint is frivolous or malicious or fails to state a claim for relief. The court evaluated the complaint under Federal Rule of Civil Procedure 8, which requires a short, plain, simple, concise, and direct statement explaining what each defendant allegedly did and why the plaintiff is entitled to relief.

The court found that the complaint did not meet those requirements. It described the allegations as needlessly long and confusing, including lengthy verbatim transcripts of conversations. The court also could not readily determine which injuries were allegedly caused by each defendant. Although the complaint included factual allegations, it broadly attributed wrongdoing to the defendants as a group, alleged that they had deprived Wilson of 33 rights, and listed more than a dozen other injuries.

The court further found that each of the 27 claims, except four, was brought against all 122 defendants and incorporated nearly all of the complaint’s factual allegations. Most claims largely repeated the legal elements without adequately explaining which alleged acts or omissions supported each defendant’s liability. As a result, the court could not determine who was being sued, for what relief, or on what legal theory.

Disposition

The court dismissed the complaint with leave to amend to correct the identified deficiencies. Wilson could file a First Amended Complaint by August 7, 2020. Any amended complaint had to clearly state how each defendant allegedly violated Wilson’s legal rights and connect each defendant to the alleged injury or injuries. Wilson could not add new claims or defendants without first obtaining the court’s permission.

The court noted that Wilson had been warned in a prior related proceeding, No. 18-cv-3973-JD, that his pleadings needed to comply with Rule 8. The court also continued the case-management conference from August 17, 2020, to October 9, 2020. Judge Maxine M. Chesney signed the order.