Bey v. United States, 1:17-cv-00162

Bey, proceeding pro se and in forma pauperis, filed suit against the United States (and referenced the City of White Plains) asserting violations of the UCC, admiralty law, and the Constitution based on events alleged to have occurred in 2003.
Pleading materials included a notice of tort claim, affidavits and instruments referencing a secured-party/creditor relationship (Anu-El) and a limited power of attorney for Bey; some filings referenced other individuals (Armstrong, Flanagan) inconsistently.
Bey asserted the United States is a corporation and the City of White Plains a sub-corporation of it, and sought relief based on apparently commercial/admiralty theories and constitutional claims.
The district court screened the complaint under 28 U.S.C. § 1915(e)(2)(B) for frivolousness and failure to state a claim, applying the Twombly/Iqbal pleading standard and Third Circuit authority on in forma pauperis screening.
The court concluded the allegations were conclusory, factually implausible (described as delusional), and legally baseless; it also noted the claims, to the extent they arose in 2003, appear time-barred.
The court denied Bey’s summary judgment motion as moot, dismissed the complaint as legally frivolous under § 1915(e)(2)(B)(i), found amendment futile, and entered judgment for dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the pro se complaint states a plausible claim under federal law	Bey claimed UCC, admiralty, and constitutional violations arising from 2003 incidents; alleged secured-party/creditor relationship and corporate status of gov't entities	(Implicit) The allegations are legally unsupported and procedurally deficient; defendant immune/claims meritless	Complaint dismissed as legally frivolous and implausible; no relief warranted
Whether the complaint is frivolous under § 1915(e)(2)(B)	Arguments rely on commercial/admiralty theories and documents purporting to create rights	Court deemed allegations conclusory, delusional, and without arguable legal basis	Dismissed as frivolous under § 1915(e)(2)(B)(i)
Whether the court should grant leave to amend	Bey sought relief via original filings; sought summary judgment	Court evaluated possibility of cure and precedents on amendment for pro se plaintiffs	Amendment found futile and denied
Whether claims are time-barred	Bey’s claims stem from 2003 events	Defendant (and court on review) noted long delay in filing (filed 2017)	Court observed claims appear time-barred on their face

Ball v. Famiglio, 726 F.3d 448 (3d Cir. 2013) (standards for dismissing in forma pauperis actions under § 1915)
Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (crediting pro se allegations and pleading standards)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se pleadings are held to less stringent standards)
Neitzke v. Williams, 490 U.S. 319 (1989) (definition of frivolous claims under § 1915)
Wilson v. Rackmill, 878 F.2d 772 (3d Cir. 1989) (frivolousness and meritless legal theories)
Tourscher v. McCullough, 184 F.3d 236 (3d Cir. 1999) (applying Rule 12(b)(6) standard to § 1915 dismissals)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (leave to amend requirement for pro se plaintiffs)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content rendering claim plausible)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading)
Johnson v. City of Shelby, 135 S.Ct. 346 (2014) (complaint need not plead particular legal theory perfectly)