QaShontae Hosomla Short v. Clint Leo Williams, Kendra Janee Giles, and Aniyah Lee Giles

Short v. Williams · United States District Court for the Eastern District of Michigan · January 9, 2026 · No. 25-13692

Summary

The United States District Court for the Eastern District of Michigan grants Plaintiff QaShontae Hosomla Short’s application to proceed without prepaying fees or costs. The court dismisses the case without prejudice under 28 U.S.C. § 1915(e)(2)(B) for failure to state a claim, concluding that the allegations concerning electronic devices, identity theft, privacy violations, and stolen funds are vague and insufficiently connected to the defendants. The court also finds that the allegations do not state a civil RICO claim.

Holdings

  1. The plaintiff satisfied the financial requirements of 28 U.S.C. § 1915(a)(1), so the court granted her application to proceed without prepaying fees or costs.
  2. The complaint failed to state a claim because its allegations were vague, conclusory, and insufficient to provide fair notice or allow a reasonable inference that any defendant was liable.
  3. Even if the civil cover sheet's reference to 'RICO ESPIONAGE PREMEDITATION' were incorporated into the complaint, the plaintiff failed to state a civil RICO claim.

Questions Presented

  1. Whether the complaint stated a plausible claim under Federal Rule of Civil Procedure 8 despite its vague and conclusory allegations.
  2. Whether the allegations, construed as a possible civil RICO claim based on the civil cover sheet, stated a claim by alleging an enterprise, a pattern of racketeering activity, and fraud with sufficient particularity.
  3. Whether the plaintiff satisfied the requirements to proceed without prepaying filing fees.

Disposition

dismissed

Cases Cited (15)

  • McGore v. Wrigglesworth, 114 F.3d 601, 608 (6th Cir. 1997)(cited)
  • Jones v. Bock, 549 U.S. 199, 127 S. Ct. 910, 166 L. Ed. 2d 798 (2007)(overruled_authority)
  • Smith v. Bernanke, 283 F. App'x 356, 357 (6th Cir. June 26, 2008)(cited)
  • Wadsworth v. United States, No. 24-13419, 2025 U.S. Dist. LEXIS 20990 (E.D. Mich. Feb. 5, 2025)(cited)
  • Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 570 (2007)(cited)
  • Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)(cited)
  • Briggs v. Westcomb, 801 F. App'x 956, 959 (6th Cir. 2020)(cited)
  • Erickson v. Pardus, 551 U.S. 89, 94 (2007)(cited)
  • Martin v. Overton, 391 F.3d 710, 714 (6th Cir. 2004)(cited)
  • Porter v. Genovese, 676 F. App'x 428, 440 (6th Cir. 2017)(cited)

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Cited In (0)

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