Jeffcoat v. Facebook Inc.

CourtDistrict Court, N.D. California
DecidedJuly 22, 2025
Docket3:25-cv-03168
StatusUnknown

This text of Jeffcoat v. Facebook Inc. (Jeffcoat v. Facebook Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffcoat v. Facebook Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ESTELA ELIZABETH JEFFCOAT, Case No. 25-cv-03168-DMR

8 Plaintiff, REQUEST FOR REASSIGNMENT TO 9 v. DISTRICT JUDGE AND REPORT AND RECOMMENDATION TO DISMISS 10 FACEBOOK INC., et al., COMPLAINT WITH LEAVE TO AMEND 11 Defendants.

12 Plaintiff Estela Elizabeth Jeffcoat filed an application for leave to proceed in forma pauperis 13 (“IFP”). [Docket No. 2.] Having considered Plaintiff’s papers, the court grants the IFP application 14 and finds that the complaint fails to state a claim on which relief may be granted pursuant to 28 15 U.S.C. § 1915(e). Plaintiff filed a declination to the jurisdiction of a magistrate judge pursuant to 16 28 U.S.C. § 636(c). [Docket No. 5.] Therefore, the court issues herein a Report and 17 Recommendation and reassigns this case to a district judge for final disposition, with the 18 recommendation that the complaint be dismissed with leave to amend. The case management 19 conference currently set for July 30, 2025 is vacated. 20 I. DISCUSSION 21 A court may allow a plaintiff to prosecute an action in federal court without prepayment of 22 fees or security if the plaintiff submits an affidavit showing that he or she is unable to pay such fees 23 or provide such security. See 28 U.S.C. § 1915(a). Having evaluated Plaintiff’s financial affidavit, 24 the court finds that s/he has satisfied the economic eligibility requirement of 28 U.S.C. § 1915(a) 25 and grants the application to proceed IFP. 26 The court’s grant of Plaintiff’s application to proceed IFP, however, does not mean that s/he 27 may continue to prosecute the complaint. A court is under a continuing duty to dismiss a case filed 1 without the payment of the filing fee whenever it determines that the action “(i) is frivolous or 2 malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief 3 against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B)(i)-(iii). If the 4 court dismisses a case pursuant to Section 1915(e)(2)(B), the plaintiff may still file the same 5 complaint by paying the filing fee. This is because the court’s section 1915(e)(2)(B) dismissal is 6 not on the merits, but rather an exercise of the court’s discretion under the IFP statute. Denton v. 7 Hernandez, 504 U.S. 25, 32 (1992). 8 To make the determination under 28 U.S.C. § 1915(e)(2)(B), courts assess whether there is 9 an arguable factual and legal basis for the asserted wrong, “however inartfully pleaded.” Franklin v. 10 Murphy, 745 F.2d 1221, 1227-28 (9th Cir. 1984). Courts have the authority to dismiss complaints 11 founded on “wholly fanciful” factual allegations for lack of subject matter jurisdiction. Id. at 1228. 12 A court can also dismiss a complaint where it is based solely on conclusory statements, naked 13 assertions without any factual basis, or allegations that are not plausible on their face. Ashcroft v. 14 Iqbal, 556 U.S. 662, 677-78 (2009); see also Erickson v. Pardus, 551 U.S. 89 (2007) (per curiam). 15 Although pro se pleadings are liberally construed and held to a less stringent standard than 16 those drafted by lawyers, see Haines v. Kerner, 404 U.S. 519, 520-21 (1972), a complaint, or portion 17 thereof, should be dismissed for failure to state a claim if it fails to set forth “enough facts to state a 18 claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 554 (2007); 19 see also Fed. R. Civ. P. 12(b)(6). “[A] district court should not dismiss a pro se complaint without 20 leave to amend unless it is absolutely clear that the deficiencies of the complaint could not be cured 21 by amendment.” Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th Cir. 2012) (quotations omitted). 22 Plaintiff brings her action against Defendants Facebook Inc., Instagram, and “Meta P. Inc.”1 23 (collectively, “Defendants”). [Docket No. 1 (Compl.) at 2.] Plaintiff alleges her “Facebook account 24 was suspended without prior notice, resulting in the loss of personal and professional resources.” 25 Id. at 3. “Despite attempts to resolve the issue, the plaintiff received no satisfactory explanation or 26 1 Elsewhere in the Complaint, Plaintiff refers to “Meta Platforms Inc.” Id. at 5-6. The court 27 assumes, for purposes of this order, that “Meta P. Inc.” and “Meta Platforms Inc.” are the same 1 resolution causing financial harm and emotional distress.” Id. at 3-4. 2 Plaintiff asserts two claims against Defendants. The first claim alleges that Defendants 3 violated “[P]laintiff’s constitutional right to privacy, as protected under the Fourth Amendment and 4 Federal laws” by suspending her Facebook account without prior notice. Id. at 5. Plaintiff’s second 5 claim is not obviously different from the first, as it also alleges a Fourth Amendment violation based 6 on Defendants’ suspension of Plaintiff’s Facebook account and failure to provide adequate 7 resolution or justification for the suspension. Id. at 6. Plaintiff seeks the restoration of her Facebook 8 account; $30,000 in damages for financial loss and emotional distress; and punitive damages for 9 negligence. Id. at 7; see id. at 4. 10 The undersigned recommends that the Complaint be dismissed with leave to amend. 11 A. Lack of Jurisdiction 12 As an initial matter, the court lacks federal question jurisdiction over this action. Plaintiff 13 alleges the court has jurisdiction “pursuant to 28 U.S.C. § 1331 because the case arise[s] under 14 Federal statutes-rights, Federal communications, [and] privacy concerns.” Compl. at 2. Federal 15 question jurisdiction under 28 U.S.C. § 1331 requires a civil action to arise under the constitution, 16 laws, or treaties of the United States. “[T]he presence or absence of federal-question jurisdiction is 17 governed by the ‘well-pleaded complaint rule,’ which provides that federal jurisdiction exists only 18 when a federal question is presented on the face of the plaintiff's properly pleaded complaint.” 19 Rivet v. Regions Bank of La., 522 U.S. 470, 475 (1998) (quoting Caterpillar, Inc. v. Williams, 482 20 U.S. 386, 392 (1987)). 21 Here, Plaintiff alleges Defendants violated her Fourth Amendment rights. However, the 22 U.S. Constitution generally does not provide a remedy for constitutional violations against private 23 actors.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Edmonson v. Leesville Concrete Co.
500 U.S. 614 (Supreme Court, 1991)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Rivet v. Regions Bank of Louisiana
522 U.S. 470 (Supreme Court, 1998)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Harry Franklin v. Ms. Murphy and Hoyt Cupp
745 F.2d 1221 (Ninth Circuit, 1984)
Javiad Akhtar v. J. Mesa
698 F.3d 1202 (Ninth Circuit, 2012)

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Bluebook (online)
Jeffcoat v. Facebook Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffcoat-v-facebook-inc-cand-2025.