Singh v. Jonas

Background

Gurpreet Singh, who represented himself, filed a complaint against numerous defendants asserting federal and California state-law claims. A magistrate judge granted Singh’s request to proceed without prepaying filing fees and recommended dismissing the case without prejudice for lack of subject-matter jurisdiction. The recommendation focused on diversity jurisdiction: Singh alleged that he and defendant Priyanka Chopra Jonas were both citizens of California, and diversity jurisdiction generally requires opposing parties to be citizens of different states.

Singh also alleged federal-law claims. Judge Susan Illston therefore reviewed the complaint to determine whether it adequately stated any federal claims that could support federal-question jurisdiction.

Court’s analysis

Because Singh was allowed to proceed without prepaying filing fees, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). That statute requires dismissal of a claim that is frivolous, fails to state a claim for relief, or seeks money from a defendant who is immune from such relief. The court applied the requirement that a complaint provide enough factual detail to make a claim plausible, while construing a self-represented plaintiff’s pleadings liberally.

Singh listed ten federal causes of action, including claims under the Computer Fraud and Abuse Act, the Lanham Act, the Federal Trade Commission Act, the Violence Against Women Act, the Identity Theft and Assumption Deterrence Act, the Interstate Stalking Punishment and Prevention Act, the Electronic Communications Privacy Act, and copyright law. He also alleged civil conspiracy and discrimination, harassment, and other civil-rights violations.

The court concluded that Singh had pleaded insufficient facts to support these claims. It stated that the complaint did not make clear what allegedly happened to him. The court also noted that some claims were presented conditionally—for example, that if defendants did something, it would constitute a federal violation—and that other allegations used the word “may.” The court required Singh to describe the alleged events and connect them to each federal cause of action.

Disposition

The court dismissed Singh’s complaint with leave to amend. It directed him to be specific about what happened and why those events violated each listed federal cause of action. The court set June 14, 2024, as the deadline to amend if Singh chose to do so. The opinion does not state that the court decided the underlying claims on their merits.