Anderson v. Ishrak

Background

Micah Anderson filed a complaint against Omar Ishrak, Medtronic, Todd Weaver, and Geoffrey Martha. He also applied to proceed without paying filing fees. The court understood the complaint to raise possible claims involving the Eighth Amendment, patents, and negligence.

Eighth Amendment claim

The complaint referred to the Eighth Amendment but provided no details about the alleged violation. The court explained that a claim under 42 U.S.C. § 1983 requires action by a state actor, and Anderson did not allege that any defendant was a state actor. The court therefore dismissed the Eighth Amendment claim as frivolous.

Patent claim

The complaint mentioned patents but did not identify any patent or describe the subject of any patent. It also contained no coherent or relevant allegations about the defendants’ conduct. The court dismissed the patent claim as frivolous.

Negligence claim and jurisdiction

The court treated negligence as a state-law claim. Anderson alleged that he resides in Illinois and that Weaver and Martha reside in Minnesota, but he did not allege the residence or citizenship of Ishrak or Medtronic. The court concluded that these allegations were insufficient to establish diversity jurisdiction. Because it dismissed the federal-law claims, the court also declined to exercise supplemental jurisdiction over the negligence claim and dismissed it for lack of subject-matter jurisdiction.

Disposition

The court concluded that the complaint was incoherent and that the federal-law claims were frivolous. It dismissed the complaint without prejudice, dismissed the negligence claim without prejudice, and denied Anderson’s applications to proceed without paying filing fees as moot. To the extent those applications sought appointed counsel, that request was also denied. Judge Wilhelmina M. Wright ordered judgment to be entered.