Edwards v. California Supreme Court

Background

The Ninth Circuit referred the matter to the district court for the limited purpose of deciding whether Myeisha M. Edwards could continue proceeding on appeal without paying court fees or whether the appeal was frivolous or taken in bad faith. Proceeding without paying court fees is commonly called proceeding in forma pauperis.

The district court had previously dismissed Edwards’s claims for lack of subject-matter jurisdiction, meaning the court concluded it lacked authority to hear them, and for failure to state a claim, meaning the complaint did not present a legally sufficient claim for relief. The court had instructed Edwards that she needed to state a claim and allege facts supporting either federal-question jurisdiction or diversity jurisdiction. The opinion states that Edwards was given an opportunity to correct those problems but did not do so.

Court’s Analysis

The court explained that an appeal is taken in good faith when it asks for review of at least one issue that is not frivolous. An issue is frivolous when it lacks an arguable legal or factual basis. The court also noted that a claim that is totally incomprehensible is frivolous.

The court found that Edwards’s complaint was incomprehensible and failed to set out facts showing that the court had jurisdiction or that Edwards was entitled to relief. It further found that Edwards had not provided facts supporting her lawsuit and had filed nonsensical and procedurally inappropriate papers. Based on those findings, the court concluded that her appeal of the dismissal order was frivolous and was not taken in good faith.

Ruling

Judge Araceli Martinez-Olguin certified that Edwards’s appeal was not taken in good faith under 28 U.S.C. § 1915(a)(3) and revoked Edwards’s permission to proceed without paying court fees on appeal. The clerk was directed to immediately notify the parties and the Court of Appeals. The opinion does not state that the district court decided the underlying claims on their merits.