Jenkins v. Minnesota School of Bartending
- Jerry Blackwell
- 0:24-cv-00621
- U.S. District Court · District of Minnesota
- 3
In Jenkins v. Minnesota School of Bartending, Judge Blackwell dismissed the complaint without prejudice and denied Jenkins’s fee-waiver application after screening.
Ardell Levert Jenkins and Minnesota School of Bartending; the action was dismissed without prejudice, and Jenkins’s application to proceed without paying filing fees was denied.
What happened
In Jenkins v. Minnesota School of Bartending, Ardell Levert Jenkins alleged that he enrolled in the school’s classes, was told he should be able to get a job after earning an A, and remained unable to find work. He also alleged that other people used “psychic powers” to harass him and that the school failed to protect him.
Jenkins sought money for emotional distress, defamation, and discrimination, and identified federal-question jurisdiction. The court found that he did not identify a federal law or explain facts showing unlawful discrimination. It also found that any possible state-law claims were conclusory and did not independently establish federal jurisdiction.
Judge Blackwell dismissed the entire action without prejudice under the federal screening statute and denied Jenkins’s application to proceed without paying filing fees. The court entered judgment accordingly.
The detailed version
- Jenkins v. Minnesota School of Bartending · No. 0:24-cv-00621
- Jerry W. Blackwell
- Apr. 1, 2024
Background
Ardell Levert Jenkins filed a complaint and an application to proceed in forma pauperis, meaning to proceed without paying filing fees. He alleged that he enrolled in classes at Minnesota School of Bartending and was told he “should be able to get a job after receiving [an] A in the college.” The complaint implied that he could not find a job despite enrolling in the classes.
Jenkins also alleged that other people had used “psychic powers” to harass him and that Minnesota School of Bartending failed to protect him. He sought monetary relief for emotional distress, defamation, and discrimination.
Court’s Analysis
The court stated that it had to consider the fee-waiver application before taking other action. Although Jenkins qualified financially for that status, the court explained that the application must be denied and the action dismissed if the complaint failed to state a legally sufficient claim under 28 U.S.C. § 1915(e)(2)(B)(ii). This review is a screening process: the court accepts factual allegations as true, but the complaint must contain enough facts to make the claimed right to relief plausible.
Jenkins checked federal-question jurisdiction under 28 U.S.C. § 1331 but did not identify the federal law supporting his claims. The court found that merely using the word “discrimination” did not explain how he was treated differently from others or whether the alleged different treatment was based on race, religion, age, or another legally protected characteristic. The court therefore found that the alleged federal claims were conclusory and did not state a claim for relief under federal law.
The court also considered possible state-law claims, including discrimination and defamation. It found those allegations conclusory as well. The court further explained that federal-question jurisdiction does not independently support state-law claims and that it would not exercise supplemental jurisdiction over those claims after dismissing all federal claims before trial.
Disposition
Judge Jerry W. Blackwell ordered that the entire action be dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B). The court also denied Jenkins’s application to proceed in forma pauperis and directed that judgment be entered.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.