Wood v. Whole Foods

Background

Michelle Yvonne Wood filed a complaint against Whole Foods and asked to proceed in the case without paying the filing fee. She stated that she was unemployed and that her only sources of income were Social Security benefits and electronic food-benefit payments. She alleged an “animal slavery” claim under the Thirteenth Amendment and sought an order preventing Whole Foods from selling meat and dairy products.

Fee status

The court granted Wood’s application to proceed without paying the filing fee. Under 28 U.S.C. § 1915, the court found that her financial circumstances met the requirements for that status.

Screening and dismissal

The court then screened the complaint. It explained that a complaint filed without payment of the filing fee may be dismissed at any time if it fails to state a claim for which relief can be granted. The court applied the same standard used for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), which asks whether the complaint alleges enough facts to support a legally plausible claim. Although Wood was representing herself and her complaint was therefore read liberally, she still had to comply with the basic pleading rules.

The court ruled that Wood’s claim was entirely implausible and that the alleged Thirteenth Amendment claim was not legally cognizable. The court also ruled that there was nothing Wood could say to make the claim plausible. It therefore dismissed the case with prejudice, meaning the dismissal barred refiling the same case. Judge James Donato signed the order.