(PS) Brosnan v. State of California

District Court, E.D. California·Decided August 12, 2025·No. 2:25-cv-00741·Unknown

Opinion

JOHN BROSNAN, Case No. 2:25-cv-00741-DC-CSK Plaintiff, ORDER AND FINDINGS AND RECOMMENDATIONS v.

(ECF Nos. 2-6) Defendant. Plaintiff John Brosnan is representing himself in this action and seeks leave to proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. § 1915.1 (ECF Nos. 2, 5.) For the reasons that follow, the Court recommends Plaintiff’s IFP applications be denied, and the First Amended Complaint (ECF No. 4) be dismissed without leave to amend. The Court further orders Plaintiff’s motions for e-filing access (ECF Nos. 3, 6) are DENIED. 28 U.S.C. § 1915(a) provides that the court may authorize the commencement, prosecution or defense of any suit without prepayment of fees or security “by a person who submits an affidavit stating the person is “unable to pay such fees or give security therefor.” This affidavit is to include, among other things, a statement of all assets the 1 This matter proceeds before the undersigned pursuant to 28 U.S.C. § 636, Fed. R. Civ. P. 72, and Local Rule 302(c). person possesses. Id. The IFP statute does not itself define what constitutes insufficient assets. See Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015). In Escobedo, the Ninth Circuit stated that an affidavit in support of an IFP application is sufficient where it alleges that the affiant cannot pay court costs and still afford the necessities of life. Id. “One need not be absolutely destitute to obtain benefits of the in forma pauperis statute.” Id. Nonetheless, a party seeking IFP status must allege poverty “with some particularity, definiteness and certainty.” Id. According to the United States Department of Health and Human Services, the current poverty guideline for a household of one (not residing in Alaska or Hawaii) is $15,650.00. See U.S. Dpt. Health & Human Service (available at https://aspe.hhs.gov/poverty-guidelines). Here, Plaintiff has made the required showing under 28 U.S.C. § 1915(a). See ECF Nos. 2, 5. However, the Court will recommend Plaintiff’s IFP applications be denied because the action is facially frivolous and without merit because it fails to state a claim. “‘A district court may deny leave to proceed in forma pauperis at the outset if it appears from the face of the proposed complaint that the action is frivolous or without merit.’” Minetti v. Port of Seattle, 152 F.3d 1113, 1115 (9th Cir. 1998) (quoting Tripati v. First Nat. Bank & Tr., 821 F.2d 1368, 1370 (9th Cir. 1987)); see also McGee v. Dep’t of Child Support Servs., 584 Fed. App’x 638 (9th Cir. 2014) (“the district court did not abuse its discretion by denying McGee's request to proceed IFP because it appears from the face of the amended complaint that McGee's action is frivolous or without merit”); Smart v. Heinze, 347 F.2d 114, 116 (9th Cir. 1965) (“It is the duty of the District Court to examine any application for leave to proceed in forma pauperis to determine whether the proposed proceeding has merit and if it appears that the proceeding is without merit, the court is bound to deny a motion seeking leave to proceed in forma pauperis.”). Because it appears from the face of the First Amended Complaint that this action is frivolous and is without merit as discussed in more detail below, the Court recommends denying Plaintiff’s IFP motions. / / / Even if the Court were to grant Plaintiff’s IFP applications, Plaintiff’s First Amended Complaint warrants dismissal pursuant to 28 U.S.C. § 1915(e)’s required pre- answer screening. Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the court accepts as true the factual allegations contained in the complaint, unless they are clearly baseless or fanciful, and construes those allegations in the light most favorable to the plaintiff. See id. at 326-27; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post-Iqbal). However, the court need not accept as true conclusory allegations, unreasonable inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). To state a claim on which relief may be granted, the plaintiff must allege enough facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the complaint and an opportunity to amend unless the complaint’s deficiencies could not be cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336, 339 (9th Cir. 1996). Plaintiff brings this action against Defendant State of California. First Amended Complaint (“FAC”) ¶ 2 (ECF No. 4). Plaintiff alleges a single cause of action for violation of his First Amendment rights pursuant to 42 U.S.C. § 1983. FAC at 2 (“this action seeks to redress the deprivation, under color of the laws, statutes, ordinances, regulations, customs and usages of the State of California [] of rights, privileges or immunities secured by the United States Constitution and by Acts of Congress.”). The entirety of the allegations in the First Amended Complaint are as follows: Plaintiff was stopped at a stoplight when the rear of the vehicle Plaintiff was driving was crashed into (“Crash”) by a vehicle driven by Emily Bouch (“EB”). Plaintiff contacted EB and obtained the insurance information for the insurer (“Insurer”) of EB, Plain

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