M-EDIF, Members of EDIF, W.MJ Boyd, Founder, also known as Wanda Boyd v. President Donald Trump, et al.

M-EDIF · United States District Court for the District of South Carolina, Charleston Division · April 19, 2026 · No. 2:26-1183-RMG

Summary

The United States District Court for the District of South Carolina adopts the magistrate judge’s Report and Recommendation and dismisses the pro se action without prejudice and without issuance or service of process. The court concludes that the plaintiff cannot bring a representative action pro se on behalf of M-EDIF and that the complaint fails to state a plausible claim.

Holdings

  1. When a party fails to file timely specific objections to a magistrate judge's Report and Recommendation, the district court need only satisfy itself that there is no clear error on the face of the record before accepting the recommendation.
  2. A pro se plaintiff cannot bring a representative action on behalf of an entity.
  3. A complaint that fails to allege facts supporting a plausible federal claim is subject to summary dismissal, even when filed by a pro se litigant.

Questions Presented

  1. What standard of review applies when no timely objection is made to a magistrate judge's Report and Recommendation?
  2. Whether a pro se plaintiff may bring a representative action on behalf of an entity.
  3. Whether the complaint alleged a plausible federal claim sufficient to avoid summary dismissal.

Disposition

dismissed

Cases Cited (5)

  • Mathews v. Weber, 423 U.S. 261, 270-71 (1976)(followed)
  • Diamond v. Colonial Life & Accident Insurance Co., 416 F.3d 310, 315 (4th Cir. 2005)(followed)
  • Cruz v. Beto, 405 U.S. 319, 322 (1972)(followed)
  • Haines v. Kerner, 404 U.S. 519, 520-21 (1972)(followed)
  • Weller v. Department of Social Services, 901 F.2d 387, 391 (4th Cir. 1990)(followed)

Cited In (0)

No citing cases on record yet.

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