Matthew Jones v. Recovery Innovations Internati, 698 F. App'x 59

Plaintiff Matthew Jones, proceeding pro se, sued Recovery Innovations after involuntary psychiatric transport and brief hospitalization, alleging spoiled food, remote (televised) psychiatric care, and administration of antipsychotics that poisoned him.
Jones alleged physical injury “from head to toe,” harm to his brain, and reputational injury from a schizophrenia diagnosis; he sought $2 billion in damages.
The complaint listed numerous federal criminal statutes, constitutional provisions, one state statute, and various case titles without connecting them to actionable claims.
The District Court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(i) as legally and factually frivolous, describing the allegations as conclusory and delusional, and declined to exercise jurisdiction over any state-law claims.
The District Court denied leave to amend as futile; Jones appealed that dismissal. The Third Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint is frivolous and subject to dismissal under 28 U.S.C. § 1915(e)(2)(B)(i)	Jones contends Recovery Innovations provided spoiled food, inadequate/remote psychiatric care, and harmful antipsychotics causing injury and reputational harm	Recovery Innovations (via District Court) effectively argued the complaint lacks any arguable legal or factual basis and contains conclusory/delusional allegations	Court held the complaint lacks an arguable basis in law or fact and is frivolous; dismissal affirmed
Whether the District Court abused its discretion by denying leave to amend	Jones implicitly sought to proceed with his claims and possibly amend	District Court found amendment futile given the pleading’s deficiencies	Court held no abuse of discretion in refusing to permit amendment
Whether the District Court should have exercised supplemental (or diversity) jurisdiction over any state-law claims	Jones asserted harms potentially arising under state law	District Court declined to exercise supplemental jurisdiction after dismissing federal claims	Court found that dismissal as frivolous was proper regardless; jurisdictional question need not be resolved
Whether extraneous arguments on appeal may be considered	Jones raised numerous unrelated issues on appeal	Appellee argued new or unrelated claims cannot be asserted first on appeal	Court declined to consider extraneous appellate arguments and affirmed dismissal

Neitzke v. Williams, 490 U.S. 319 (establishing that a complaint may be dismissed as frivolous when it lacks an arguable basis in law or fact)
Connelly v. Steel Valley Sch. Dist., 706 F.3d 209 (3d Cir. 2013) (standard for reviewing district court refusal to permit amendment)
In re Reliant Energy Channelview LP, 594 F.3d 200 (3d Cir. 2010) (plaintiff may not raise new claims for the first time on appeal)