Albury III v. Strategic Staffing Solutions, 2:24-cv-02003

Samuel J. Albury III filed a complaint in the District of Nevada alleging employment discrimination, seeking to proceed in forma pauperis (without paying court fees).
Albury claimed he suffered race and age discrimination and retaliation by Strategic Staffing Solutions, his former employer.
Plaintiff’s application to proceed in forma pauperis was granted as he demonstrated inability to pay the court fees.
All alleged discriminatory acts and employment events occurred outside Nevada; the defendant is based in Michigan, and plaintiff worked in Florida.
The court reviewed the complaint to determine if it stated valid claims and whether the court had personal jurisdiction over the defendant.
The court concluded it lacked personal jurisdiction and dismissed the case without prejudice, giving leave to amend if jurisdictional facts can be shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
In forma pauperis eligibility	Cannot pay fees; seeks IFP status	—	Granted
Personal jurisdiction over defendant	Sufficient for suit in Nevada	Defendant out-of-state, all events elsewhere	No jurisdiction; complaint dismissed
Discrimination (Title VII & ADEA)	Suffered race and age discrimination	—	Pleads sufficient facts for claims; jurisdiction lacking
Retaliation claim	Terminated soon after complaining	—	Sufficient facts alleged; jurisdiction lacking

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standard: complaints require more than labels and conclusions)
Ashcroft v. Iqbal, 556 U.S. 662 (complaints need factual allegations to plausibly state a claim)
Hughes v. Rowe, 449 U.S. 5 (pro se pleadings held to less stringent standards)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (specific jurisdiction arises from defendant's forum activity)
Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (specific jurisdiction requires purposefully directed activities in the forum)
Neitzke v. Williams, 490 U.S. 319 (claims can be dismissed as fanciful or legally untenable)