Johnson v. King County Superior Court
2:25-cv-01533
| W.D. Wash. | Aug 20, 2025Background
- Plaintiff Ingrid Johnson sought to proceed in forma pauperis (IFP) in the U.S. District Court for the Western District of Washington.
- Plaintiff's complaint alleged OpenAI interfered with her ability to file legal motions by degrading or censoring its services during an active federal case.
- Johnson claimed this constituted digital obstruction of justice and denial of due process, as well as violations under 42 U.S.C. § 1983 and the Americans with Disabilities Act (ADA).
- The court acknowledged Johnson’s status as a vexatious litigant in state court and noted profanity-laden communications directed at the court.
- The case was reviewed sua sponte under 28 U.S.C. § 1915(e)(2)(B), requiring dismissal if the complaint fails to state a claim.
- The court granted the IFP application but dismissed the complaint without prejudice, granting leave to amend within 14 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| § 1983: State action by OpenAI | OpenAI acted as a gatekeeper, possibly under color of law | No showing OpenAI is a state actor | No state action; claim dismissed |
| ADA: Discrimination by a public entity or accommodation | OpenAI's actions denied ADA rights | OpenAI is not a public entity or public accommodation | No ADA claim stated; claim dismissed |
| Consumer protection and conspiracy claims | OpenAI breached consumer protections and conspired against her | No disclosed argument; court found no legal basis | No viable legal theory; claims dismissed |
| IFP, court decorum, sanctions | Sought IFP due to indigency | Court noted profane conduct | IFP granted; warning of future sanctions given |
Key Cases Cited
- Sprewell v. Golden State Warriors, 266 F.3d 979 (9th Cir. 2001) (court need not accept conclusory/legal allegation as true when considering dismissal)
- Jensen v. Lane Cty., 222 F.3d 570 (9th Cir. 2000) ("color of law" under § 1983 equates to constitutional state action requirement)
- Where Do We Go Berkeley v. California Dep’t of Transportation, 32 F.4th 852 (9th Cir. 2022) (sets ADA Title II pleading requirements)
- Langer v. Kiser, 57 F.4th 1085 (9th Cir. 2023) (explains ADA Title III scope re: public accommodations)
- Lucas v. Dep’t of Corr., 66 F.3d 245 (9th Cir. 1995) (leave to amend should be granted unless defect is incurable)