Lewis v. Zuckerberg
- Jacquelyn Corley
- 3:23-cv-04143
- U.S. District Court · Northern District of California
- 3
Judge Corley dismissed Lewis v. Zuckerberg as frivolous after screening Lewis’s federal-prisoner complaint.
James D. Lewis’s complaint was dismissed; the defendants named in the complaint were Mark Zuckerberg, Facebook, Meta, the Internal Revenue Service, the Federal Communications Commission, and other unidentified defendants.
What happened
In Lewis v. Zuckerberg, James D. Lewis, a federal prisoner without a lawyer, sued Mark Zuckerberg, Facebook, Meta, federal agencies, and other unidentified defendants. He alleged enormous investments in technology and credit-card companies and listed numerous legal theories.
The court screened the complaint under laws requiring review of prisoner and fee-waived cases. It found Lewis’s allegations that he invested hundreds of billions of dollars and could claim more than $21 trillion were wholly incredible and dismissed the complaint as frivolous.
Judge Jacquelyn Scott Corley dismissed the case without leave to amend, ordered the clerk to enter judgment, and closed the file.
The detailed version
- Lewis v. Zuckerberg · No. 3:23-cv-04143
- Jacquelyn Corley
- Sept. 15, 2023
Background
James D. Lewis, a federal prisoner proceeding without an attorney, filed a civil complaint against Mark Zuckerberg, Facebook, Meta, the Internal Revenue Service, the Federal Communications Commission, and other unidentified defendants. The court separately granted him permission to proceed without paying the filing fee.
Lewis alleged that, in April or May 2023, he placed $200 billion in each of eight technology companies and $486 billion in each of four credit-card companies. He also referred to a worldwide contest or challenge involving Elon Musk, Mark Zuckerberg, and the Threads application. The complaint listed numerous alleged violations, including securities and investment statutes, the Telecommunications Act, the Americans with Disabilities Act, several constitutional amendments, the Uniform Commercial Code, and other laws. Lewis sought to have the allegations addressed and claimed he could apply more than $21 trillion as leverage through his tax forms.
Screening and Analysis
The court explained that federal law requires preliminary screening of a prisoner’s complaint seeking relief from a governmental entity or employee. The court must dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. A separate statute also requires dismissal of a case filed without the filing fee when one of those conditions exists.
The court defined a frivolous claim as one based on an indisputably meritless legal theory or facts with no factual basis. It may disregard factual allegations during screening when they are irrational or wholly incredible, although it may not dismiss allegations merely because they seem unlikely or improbable.
The court found Lewis’s allegations that he invested hundreds of billions of dollars in the identified companies and could claim or use more than $21 trillion to be “wholly incredible and delusional.” It therefore found the claims frivolous under the prisoner-screening and fee-waiver statutes.
Disposition
The court dismissed the case without leave to amend as frivolous. It directed the clerk to enter judgment and close the file. Judge Jacquelyn Scott Corley signed the order on September 15, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.