Jones v. Recovery Innovations International, 1:17-cv-00396

Pro se plaintiff Matthew Jones filed suit against Recovery Innovations International after being held for psychiatric evaluation and transfer among Seaford Nanticoke Hospital, Recovery Innovations, and Dover Behavioral Health on Jan 31–Feb 1, 2017.
Jones alleges improper detention, spoiled/rancid food, a remote psychiatrist, a schizophrenia diagnosis, and broader claims of persecution and rights deprivation; he seeks $2 billion in damages.
The case was transferred to the District of Delaware; Jones proceeds in forma pauperis and the Court screened the complaint under 28 U.S.C. § 1915(e)(2)(B).
The Court characterized Jones’s allegations as conclusory, legally and factually frivolous, and including some delusional assertions beyond a plausible factual basis.
The Court concluded the complaint failed to state a federal claim and dismissed it as frivolous, finding amendment would be futile.
The Court declined to exercise supplemental jurisdiction over any state-law claims given the lack of viable federal claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Complaint is frivolous or fails to state a claim under § 1915(e)(2)(B)	Jones contends Recovery Innovations unlawfully deprived him of rights during psychiatric detention and seeks damages	Implicit defense: allegations lack legal merit and factual support	Court: Complaint is frivolous and does not state a plausible federal claim; dismissed under § 1915(e)(2)(B)(i)
Whether leave to amend should be granted	Jones implicitly seeks relief via his complaint	Court must consider liberal amendment for pro se filings	Court: Amendment would be futile; dismissal is with prejudice to amendment for federal claims
Whether to retain supplemental state-law claims	Jones asserts various state-law violations as well	Defendant did not press on supplemental jurisdiction after federal claims fail	Court: Declines to exercise supplemental jurisdiction over state-law claims (28 U.S.C. § 1367)

Ball v. Famiglio, 726 F.3d 448 (3d Cir.) (§ 1915 screening standard for in forma pauperis suits)
Neitzke v. Williams, 490 U.S. 319 (U.S.) (definition of frivolous and meritless claims)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S.) (pleading must state plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S.) (plausibility standard and courts may use judicial experience/common sense)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir.) (leave to amend ordinarily required for § 1915 dismissals unless futile)
Tourscher v. McCullough, 184 F.3d 236 (3d Cir.) (§ 1915(e)(2)(B) uses Rule 12(b)(6) standard)