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

Background

Michael Geary Wilson filed a document titled “Incomplete & Incorrect First Amended & Supplemented Complaint for Injunctive Relief, Setting Aside Orders & Judgments, Damages, and Other Relief.” The court construed that filing as his First Amended Complaint (FAC). The opinion also notes that Wilson filed another document with a similar title on August 24, 2020, after the deadline to amend; the court stated that this document had the same deficiencies.

The court had previously dismissed Wilson’s initial complaint under Rule 8 of the Federal Rules of Civil Procedure. That complaint contained 198 pages of text, 27 claims for relief, and 122 defendants. The court had given Wilson permission to amend, instructing him to provide a short, simple, concise, and direct statement explaining the alleged wrongdoing of each defendant and clearly linking each defendant to the alleged injury.

Court’s Analysis

Because Wilson was proceeding without paying the filing fee, the court screened the FAC under 28 U.S.C. § 1915(e)(2). That statute requires dismissal if the complaint is frivolous or malicious or fails to state a claim on which relief may be granted.

The court found that the FAC compounded the defects in the initial complaint. It was 609 pages long, asserted 47 claims for relief, and named 222 defendants, including a school district, local governments, California superior courts, government officials, superior court judges, police officers, and private parties. The FAC also included lengthy verbatim transcripts, including one transcript extending for more than 100 pages.

The court further found that the FAC did not clearly identify how each defendant allegedly violated Wilson’s legal rights. All but five of the claims were brought against all 222 defendants, and each claim incorporated the preceding factual allegations, which exceeded 500 pages. The court said that the claims largely amounted to formulaic statements of legal elements and did not identify the acts or omissions supporting any particular defendant’s liability.

The FAC also broadly alleged that the defendants’ “wrongful acts” deprived Wilson of more than 30 rights and caused more than a dozen injuries. In the court’s view, the pleading still did not provide clear and concise allegations showing which defendants were liable for which wrongs or what relief and legal theories were being asserted.

Disposition

The court found that Wilson had not cured the Rule 8 defects despite the prior dismissal, repeated warnings, and detailed amendment instructions. It determined that further amendment would be futile. Judge Maxine M. Chesney ordered that the action be dismissed with prejudice.