Berry v. Meta Platforms

Summary

The United States District Court for the Northern District of California ordered pro se plaintiff Quincy K. Berry to show cause why his renewed application to proceed in forma pauperis should not be denied and why his complaint should not be dismissed. The court identified deficiencies concerning Berry’s financial disclosures, failure to pay the filing fee, subject-matter jurisdiction, and the conclusory allegations that Meta Platforms, Mark Zuckerberg, Facebook, and Instagram acted under color of law. Berry was directed by July 3, 2025, to pay the filing fee or explain his eligibility for in forma pauperis status and to amend the complaint or explain why it should proceed.

Holdings

1. The renewed application did not adequately explain how Berry could meet his reported monthly expenses despite reporting no income or assets, so the court ordered him to show cause why the application should not be denied.
2. A complaint proceeding, or seeking to proceed, in forma pauperis may be dismissed if it is frivolous or fails to state a claim, and conclusory recitations of legal elements are insufficient; Berry's complaint therefore required a response or amendment addressing specific factual deficiencies.
3. A complaint must provide a sufficient basis for federal subject matter jurisdiction; alleging that a breach-of-contract dispute violates due process does not, by itself, establish federal-question jurisdiction.

Questions Presented

1. Whether Berry's renewed application to proceed in forma pauperis adequately established his inability to pay the filing fee.
2. Whether the complaint should be dismissed or required to be amended because it failed to state a plausible claim and appeared potentially frivolous.
3. Whether the complaint adequately established federal subject matter jurisdiction under federal-question or diversity jurisdiction.

Disposition

other