Patrick L. Mays v. Madison County Catholic Charities Diocese of Springfield in Illinois, Denise Burton, and Sheryll Kellum

Summary

The United States District Court for the Southern District of Illinois reserved ruling on Patrick L. Mays’s motion to proceed in forma pauperis and dismissed his complaint without prejudice. The court concluded that allegations concerning a disciplinary notice did not state a claim under the cited federal laws or establish federal-question jurisdiction, and that diversity jurisdiction was unavailable because all parties were Illinois citizens and the claimed damages were $70,000. The court granted Mays until May 27, 2026, to file an amended complaint.

Holdings

1. The complaint failed to state a claim under the Sherman Antitrust Act, the FOIA Improvement Act of 2016, the Economic Espionage Act of 1996, the First Amendment, or any federal employment statute, and therefore did not establish federal-question jurisdiction.
2. The complaint did not establish original diversity jurisdiction because all parties were Illinois citizens and Plaintiff sought only $70,000 in damages.
3. Although Plaintiff was indigent, the court dismissed the complaint without prejudice under 28 U.S.C. § 1915(e)(2) and reserved ruling on the motion for leave to proceed in forma pauperis.

Questions Presented

1. Whether the complaint stated a claim under the Sherman Antitrust Act, the FOIA Improvement Act of 2016, the Economic Espionage Act of 1996, the First Amendment, or a federal employment statute sufficient to invoke federal-question jurisdiction.
2. Whether the complaint established diversity jurisdiction under 28 U.S.C. § 1332(a).
3. Whether the complaint should be dismissed under 28 U.S.C. § 1915(e)(2) while the motion for leave to proceed in forma pauperis remained pending.

Disposition

dismissed