Lewis v. Indiana National Guard

Summary

The United States District Court for the Southern District of Indiana grants Jahlil J. Lewis’s motion to proceed in forma pauperis. The court dismisses his complaint against the Indiana National Guard without prejudice as factually frivolous and for lack of subject-matter jurisdiction, while ordering him to show cause by April 23, 2026, why final judgment should not issue and warning of possible filing restrictions.

Holdings

1. Plaintiff's motion to proceed in forma pauperis was granted because his submission met the statutory standard for demonstrating an inability to prepay the filing fee.
2. The complaint was factually frivolous and subject to dismissal under 28 U.S.C. § 1915(e)(2)(B) because its allegations were delusional and rose to the level of the irrational or wholly incredible.
3. Because the complaint was factually frivolous, it did not invoke federal subject-matter jurisdiction, and dismissal was necessarily without prejudice.

Questions Presented

1. Whether Plaintiff qualified to proceed in forma pauperis under 28 U.S.C. § 1915(a)(1).
2. Whether the complaint was subject to dismissal at screening under 28 U.S.C. § 1915(e)(2)(B) because its allegations were factually frivolous.
3. Whether a factually frivolous complaint invokes federal subject-matter jurisdiction and, if not, whether dismissal should be without prejudice.

Disposition

dismissed