Unreported / Non-Citable
Background
Charles Edward Payne, Jr. sued Donald Trump, several entities, and multiple named and unnamed landlords. His complaint described his claim as involving identity theft dating to 1982, a general warranty deed, a lien, and United States property, but provided no further factual details.
Payne submitted numerous exhibits, including identification, warranty deeds, police reports, tax records, public-benefit documents, receipts, Social Security documents, and conversations with artificial intelligence. Although he checked boxes asserting diversity and federal-question jurisdiction, he cited no law and listed his own name in response to questions about citizenship. He sought land, housing, his son’s release from CPS, and payment from his savings.
The Court’s Holding
The court granted Payne’s application to proceed in forma pauperis but dismissed his claims without prejudice under 28 U.S.C. § 1915(e)(2)(B). It held that the disjointed allegations and filings were frivolous and failed to state a claim on which relief could be granted.
The court could not discern a plausible cause of action from the complaint or its exhibits. It also found that Payne cited no applicable law, did not fully identify the defendants, failed to connect any defendant to the alleged wrongdoing or requested relief, and sought no proper relief. All pending motions were denied as moot, and the court stated that it would enter a separate final judgment.
Key Takeaways
- A court must screen an in forma pauperis action and dismiss claims that are frivolous or fail to state a claim.
- Disjointed allegations and voluminous exhibits do not establish a plausible claim when the complaint identifies no viable legal theory or supporting facts.
- A complaint must identify the defendants, connect each defendant to the alleged conduct, and request legally available relief.
Why It Matters
The decision illustrates the pleading requirements applied during screening under 28 U.S.C. § 1915(e)(2)(B). Even when in forma pauperis status is granted, a complaint cannot proceed unless its factual allegations and legal theory provide an arguable basis for relief against identifiable defendants.