Anderson v. Ishrak
- Wilhelmina Wright
- 0:22-cv-00426
- U.S. District Court · District of Minnesota
- 4
In Anderson v. Ishrak, Judge Wright dismissed the lawsuit without prejudice as frivolous and for lack of jurisdiction, and denied Anderson’s applications as moot.
The dismissal affected Micah Anderson’s claims against Omar Ishrak, Medtronic, Todd Weaver, and Geoffrey Martha. The court dismissed the lawsuit without prejudice and denied Anderson’s applications to proceed in forma pauperis as moot.
What happened
In Anderson v. Ishrak, Micah Anderson’s complaint mentioned claims involving the Eighth Amendment, patents, and negligence against Omar Ishrak, Medtronic, Todd Weaver, and Geoffrey Martha. He also applied to proceed without paying the usual filing costs.
The court found that Anderson did not allege that any defendant was a state actor or provide details supporting an Eighth Amendment claim. It also found that he did not identify any patent or provide coherent allegations supporting patent infringement. The court concluded that it lacked authority to hear the negligence claim because Anderson had not provided enough information to establish the required citizenship of the parties and amount in controversy.
Judge Wilhelmina M. Wright dismissed the lawsuit without prejudice and denied Anderson’s applications as moot. The court also declined to hear the negligence claim after dismissing the federal claims.
The detailed version
- Anderson v. Ishrak · No. 0:22-cv-00426
- Wilhelmina Wright
- Aug. 12, 2022
Background
Micah Anderson filed a complaint against Omar Ishrak, Medtronic, Todd Weaver, and Geoffrey Martha. The complaint referred to the Eighth Amendment, patents, and negligence. Anderson also filed applications to proceed in forma pauperis, meaning applications to proceed without paying the required filing costs. The court stated that the complaint and attached exhibits were incoherent and did not provide enough detail to identify the claims clearly.
Eighth Amendment claim
The court explained that a claim under 42 U.S.C. § 1983 generally requires action by a state actor. Anderson did not allege that any defendant was a state actor. He also provided no details about the alleged Eighth Amendment violation beyond mentioning the amendment. The court therefore dismissed the Eighth Amendment claim as frivolous, meaning lacking an arguable legal or factual basis.
Patent claim
The court stated that a patent-infringement claim requires identifying the patent and comparing its claims with the allegedly infringing device. Anderson did not identify any patent or describe the subject of any patent. The complaint also contained no coherent or relevant allegations about the conduct of the defendants. The court dismissed the patent claim as frivolous.
Negligence claim and jurisdiction
The court treated negligence as a state-law claim. It explained that federal-question jurisdiction does not cover a state-law claim by itself. Diversity jurisdiction requires, among other things, that every defendant be a citizen of a different state from the plaintiff and that the amount in controversy exceed $75,000. Anderson alleged that he resided in Illinois and that Weaver and Martha resided in Minnesota, but he did not allege the residency or citizenship of Ishrak or Medtronic. The court concluded that Anderson had not alleged facts sufficient to establish subject-matter jurisdiction, meaning the court’s legal authority to hear the claim.
The court also stated that after dismissing all federal-law claims, it typically should not exercise supplemental jurisdiction—the authority to hear related state-law claims—over the remaining negligence claim. It therefore declined to exercise supplemental jurisdiction and dismissed the negligence claim for lack of subject-matter jurisdiction.
Disposition
The court dismissed the federal-law claims without prejudice, dismissed the state-law negligence claim without prejudice, and dismissed the lawsuit without prejudice. It denied Anderson’s applications to proceed in forma pauperis as moot. The court also denied any request for appointment of counsel made through those applications. Judge Wilhelmina M. Wright signed the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.