Caseflicks

District Court, W.D. Pennsylvania • 1971

United States ex rel. Mayo v. Satan & His Staff

54 F.R.D. 282 | 1971 U.S. Dist. LEXIS 10548

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Takeaway

In short, this case shows that in forma pauperis status may be denied when a proposed complaint presents fundamental doubts about a viable claim, personal jurisdiction, and the ability to move the case forward procedurally.

Background

The plaintiff sought leave to file and prosecute an in forma pauperis civil-rights complaint against Satan and his staff. Invoking 18 U.S.C. § 241, 28 U.S.C. § 1343, and 42 U.S.C. § 1983, he alleged that Satan had caused him misery, made unwarranted threats, placed deliberate obstacles in his path, and caused his downfall, thereby depriving him of constitutional rights.

The district court considered the application before allowing the action to proceed. It identified serious problems with the legal sufficiency of the proposed complaint, personal jurisdiction over the defendant, possible class-action treatment, and the plaintiff's failure to supply instructions enabling the United States Marshal to serve process. Exercising its discretion, the court denied in forma pauperis status and assigned the matter a miscellaneous docket number.

Issues

Issue #1

Whether the plaintiff should be permitted to file and proceed with the action in forma pauperis.

Holding

No. The court denied leave to proceed in forma pauperis.

Reasoning

Although the court assumed for purposes of its discussion that the complaint might contain a prima facie allegation of civil-rights infringement, that assumption did not require the court to authorize a pauper action. The court retained discretion to deny the application where substantial threshold defects made the proposed litigation doubtful.

The proposed complaint presented serious unresolved obstacles. The court doubted whether it stated a cause of action on which judicial relief could be granted and questioned whether the defendant could be subjected to the court's authority in the Western District of Pennsylvania.

The plaintiff also failed to include the required directions to the United States Marshal for service of process. Taken together with the jurisdictional and merits concerns, that omission supported the court's decision not to permit the case to proceed in forma pauperis.

Issue #2

Whether the court had personal jurisdiction over Satan in the Western District of Pennsylvania.

Holding

The court did not resolve the question, but held that the complaint failed to establish a basis for personal jurisdiction in the district.

Reasoning

The complaint did not allege that Satan resided in the Western District of Pennsylvania or otherwise identify facts connecting him to the district. Without such allegations, the court had serious doubts that it could obtain personal jurisdiction over the defendant.

Judge Weber noted an unofficial account of a New Hampshire proceeding in which Satan supposedly appeared as a mortgage-foreclosure plaintiff. That account suggested a possible dispute over Satan's legal status and whether a prior position might create estoppel, but the court expressly declined to determine the issue at that stage.

Issue #3

Whether the proposed suit could be maintained as a class action.

Holding

The court did not decide whether class treatment was proper.

Reasoning

The court observed that the proposed action appeared to satisfy several Rule 23 considerations: the putative class was too numerous for practical joinder, common questions of law and fact existed, and the named plaintiff's claims appeared typical of those of the class.

But Rule 23 also requires that the representative fairly and adequately protect absent class members' interests. Because the court could not determine whether the plaintiff met that requirement, it left class certification unresolved rather than allowing the case to proceed as a class action.