Doe v. Atlanta Center for Self Sufficiency, 1:17-cv-03513

Plaintiff Jane Doe, proceeding pro se and in forma pauperis, filed a one‑page complaint alleging that Atlanta Center for Self Sufficiency and unnamed Does improperly disclosed her “legally protected information,” retaliated against her, and removed her from a program.
Complaint asserted federal Fourth Amendment claim and state claims (invasion of privacy, intentional/negligent infliction of emotional distress, harassment, stalking) and sought $999 million.
Magistrate judge granted IFP and the district court conducted the required frivolity review under 28 U.S.C. § 1915(e)(2)(B).
The Court found no factual allegations showing Defendants were state actors or that any government involvement occurred to bring the conduct within the Fourth Amendment.
The Court dismissed the Fourth Amendment claim as frivolous and for failure to state a claim; declined to exercise supplemental jurisdiction over state law claims and dismissed them without prejudice.
All pending motions by Plaintiff (including to proceed as Jane Doe, for counsel, and to preserve evidence) were denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether alleged disclosure implicates Fourth Amendment	Doe alleges Defendants disclosed her protected information, violating her Fourth Amendment rights	Defendants are a private nonprofit and did not act as government agents	Dismissed: Fourth Amendment applies only to state action; complaint lacks allegations of state involvement or unreasonable search/seizure
Whether complaint states a plausible federal claim	Doe contends the facts alleged support federal constitutional relief	Defendants argue allegations are conclusory and insufficient under Twombly/Iqbal standards	Dismissed as frivolous and for failure to state a claim; allegations are labels/conclusions without factual support
Whether to retain supplemental jurisdiction over state claims	Doe seeks relief on state tort claims related to the disclosure and alleged retaliation	Defendants (implicitly) argue federal claim fails, so state claims should be resolved in state court	Court declines supplemental jurisdiction and dismisses state claims without prejudice
Whether Doe may proceed against Doe defendants	Doe named Does 1–100 as unnamed defendants	Federal practice disfavors fictitious‑party pleading absent specific identifying facts	Doe defendants dismissed because pleading of fictitious parties is not permitted

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual allegations that plausibly suggest liability)
Bell Atlantic v. Twombly, 550 U.S. 544 (2007) (claims must rise above mere possibility; labels and conclusions insufficient)
Neitzke v. Williams, 490 U.S. 319 (1989) (frivolousness standard permits dismissal of clearly baseless factual allegations)
Miller v. Donald, 541 F.3d 1091 (11th Cir. 2008) (frivolity review allows district court to pierce complaint veil and dismiss claims clearly baseless)
Carroll v. Gross, 984 F.2d 392 (11th Cir. 1993) (frivolous claim defined as one with little or no chance of success)
Mitchell v. Farcass, 112 F.3d 1483 (11th Cir. 1997) (§ 1915(e)(2)(B) failure‑to‑state standard parallels Rule 12(b)(6))
United States v. Jacobsen, 466 U.S. 109 (1984) (Fourth Amendment applies only to governmental action)
Rayburn ex rel. Rayburn v. Hogue, 241 F.3d 1341 (11th Cir. 2001) (tests for private party to be treated as state actor)