Elam v. Snapchat, Inc.

• Court: District Court, N.D. California
• Decided: June 4, 2025
• Docket: 3:25-cv-03827
• Status: Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ERIC JORDAN ELAM, 1001453590, Case No. 25-cv-03827-CRB (PR)

8 Plaintiff, ORDER OF DISMISSAL 9 v.

10 SNAPCHAT, INC., et al., 11 Defendant(s).

12 I. 13 Plaintiff, a prisoner at Dooly State Prison in Unadilla, Georgia, has filed a pro se complaint 14 alleging that Snapchat, Inc., Meta Platforms, Inc., and Verizon Wireless violated the Stored 15 Communications Act (SCA), 18 U.S.C. §§ 2701-2713, when they disclosed his electronic 16 communications to law enforcement pursuant to a search warrant issued in March 2021 by 17 Cherokee County Magistrate Court. Plaintiff argues that the Cherokee County Magistrate Court 18 does not qualify as a “court of competent jurisdiction” under § 2703(a) because it lacks general criminal jurisdiction as required by federal law. 19 Plaintiff seeks damages and declaratory relief, and also leave to proceed in forma pauperis 20 (IFP) under 28 U.S.C. § 1915. 21 II. 22 A federal court shall dismiss a case filed IFP at any time if it determines that the action is 23 “frivolous or malicious,” “fails to state a claim on which relief may be granted” or “seeks 24 monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2). 25 III. 26 The SCA provides that “court of competent jurisdiction” includes “a court of general 27 ] U.S.C. § 2711. Georgia magistrate courts are courts of limited jurisdiction, in that among other 2 || things they do not have power to issue process in the nature of mandamus, prohibition, specific 3 || performance, quo warranto, and injunction. Ga. Const. art. VI, § 1, 991, 1V. But Georgia law 4 || specifically provides that Georgia magistrate courts may issue warrants. See Ga. Code § 17-4-40 5 (“[a]ny judge of a superior, city, state, or magistrate court or any municipal officer clothed by law 6 || with the powers of a magistrate may issue a warrant for the arrest of any offender . . .”); Ga. Code 7 § 15-10-2(a)(1) (“Each magistrate court and each magistrate thereof shall have jurisdiction and 8 || power over the following matters: (1) The hearing of applications for and the issuance of arrest 9 || and search warrants ...”). 10 To be a court of competent jurisdiction within the meaning of § 2711 requires that the 11 court have the authority to issue warrants. See Hubbard v. MySpace, Inc., 788 F. Supp. 2d 319, 12 || 324(S.D.N.Y. 2011) (in context of SCA, court of competent jurisdiction “implicates a judicial 13 officer’s authority to issue warrants, not to try cases; holding that warrant issued by Cherokee 14 || County magistrate court was not invalid due to fact issuing magistrate could not have presided 3 15 over criminal trial of user). The Cherokee County Magistrate Court is a court of competent 16 || jurisdiction within the meaning of § 2711 because it is authorized to issue warrants. See id. i 17 || Plaintiffs allegations therefore fail to state a claim for violation of the SCA. 18 IV. 19 For the foregoing reasons, the complaint is DISMISSED under 28 U.S.C. § 1915(e)(2) for 20 || failure to state a claim on which relief may be granted. 21 The clerk shall close the case and terminate all pending motions as moot. 22 IT IS SO ORDERED. 23 || Dated: June 4, 2025 24 Lo 5 — CHARLES R. BREYER 25 United States District Judge 26 27 28