Kimberly Y. Mims, et al. v. California Legislative Black Caucus, et al.

Summary

The United States District Court for the Eastern District of California grants Kimberly Y. Mims and Darlene Crumedy leave to proceed in forma pauperis. The magistrate judge recommends dismissal without leave to amend, concluding that the federal claims are barred by legislative immunity, subject-matter jurisdiction is lacking, and supplemental jurisdiction over the state-law claims should be declined. The findings and recommendations were issued on December 9, 2025, and permit objections within 14 days.

Holdings

1. Pro se plaintiffs may not represent other individuals in a class action; allegations referring to individuals who are not named plaintiffs will be disregarded.
2. The federal constitutional claims under 42 U.S.C. § 1983 were barred by absolute legislative immunity because they challenged legislative acts and policymaking activities within the sphere of legitimate legislative activity.
3. The complaint did not establish subject matter jurisdiction because the federal claims were barred by legislative immunity and the complaint did not establish complete diversity of citizenship.
4. The court should decline supplemental jurisdiction over the state-law claims because plaintiffs failed to state a claim under federal law.
5. Leave to amend should be denied because the complaint's deficiencies could not be cured by amendment.

Questions Presented

1. Whether pro se plaintiffs may represent other individuals in a putative class action.
2. Whether the federal constitutional claims against the legislative defendants and Governor Newsom were barred by absolute legislative immunity.
3. Whether the complaint established federal-question or diversity subject matter jurisdiction.
4. Whether the court should exercise supplemental jurisdiction over the state-law claims after determining that the federal claims could not proceed.
5. Whether plaintiffs should be granted leave to amend.

Disposition

dismissed