Matthew Aaron Simpson, II v. State of Michigan

Summary

The United States District Court for the Eastern District of Michigan grants Matthew Aaron Simpson’s application to proceed in forma pauperis and screens his complaint under 28 U.S.C. § 1915(e)(2)(B). The court dismisses the complaint without prejudice because sovereign immunity bars the action against Michigan and 15 U.S.C. § 1667(5) is a definitions provision that does not support the asserted claim. Related filing and sealing motions are dismissed as moot, and Simpson is given until December 9, 2025, to amend.

Holdings

1. Simpson made the required showing of indigence under 28 U.S.C. § 1915(a)(1), so the court granted his application to proceed in forma pauperis.
2. The complaint against the State of Michigan was barred by sovereign immunity and therefore failed preliminary screening.
3. The complaint failed to state a viable claim based on 15 U.S.C. § 1667(5) because that provision is merely a definitions provision of the Truth in Lending Act.
4. The notice of filing and motion to seal were dismissed as moot following dismissal of the complaint.

Questions Presented

1. Whether Simpson established indigence sufficient to proceed in forma pauperis.
2. Whether the complaint was subject to dismissal under 28 U.S.C. § 1915(e)(2)(B) because sovereign immunity barred the action against the State of Michigan.
3. Whether the complaint stated a viable claim based on 15 U.S.C. § 1667(5).
4. Whether Simpson's notice of filing and motion to seal should be dismissed as moot after dismissal of the complaint.

Disposition

dismissed