Mendillo v. Brookside Properties, Inc, 1:25-cv-00275

Plaintiff Alexander Mendillo filed this pro se complaint in the Eastern District of Tennessee seeking relief for mold-related injuries in his apartment.
Plaintiff sought in forma pauperis status, which the court preliminarily evaluates under 28 U.S.C. § 1915(e)(2).
The court screens for jurisdiction and finds the complaint does not state actionable claims or a private right of action for criminal statutes cited by plaintiff.
Plaintiff names numerous defendants and lays out generally related allegations, many not clearly connected to the mold claim.
The court determines federal claims are deficient and lacks subject matter jurisdiction, and will dismiss and deny IFP as moot if appropriate.
The court also notes it would decline supplemental jurisdiction over state-law claims once federal claims are dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal claims are jurisdictionally cognizable	Mendillo relies on federal question jurisdiction under 28 U.S.C. § 1331	Defendants contend the cited criminal statutes do not create private rights of action and lack jurisdiction	Lacking private right; federal claims dismissed
Whether criminal statutes provide a private right of action	Plaintiff seeks relief under 18 U.S.C. §§ 241–249, 1519	Criminal statutes do not created private civil actions	Criminal statutes do not provide a private right of action; dismissal appropriate
Whether state-law claims should be dismissed for lack of jurisdiction	Plaintiff asserts various state-law violations	No federal question remains to support supplemental jurisdiction	Decline to exercise supplemental jurisdiction; state claims dismissed as appropriate

Neitzke v. Williams, 490 U.S. 319 (1989) (frivolousness and dismissal in IFP actions; screening standards)
Brand v. Motley, 526 F.3d 921 (6th Cir. 2008) (12(b)(6) plausibility standard applied to IFP complaints)
Thomas v. Eby, 481 F.3d 434 (6th Cir. 2007) (reiterates pleading standards for federal claims)
Erickson v. Pardus, 551 U.S. 89 (2007) (liberal pleading standard for pro se litigants)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard refined after Twombly)
Renne v. Geary, 501 U.S. 312 (1991) (presumption of lack of jurisdiction; dismissal if not shown)
Bender v. Williamsport Area Sch. Dist., 475 U.S. 534 (1986) (jurisdictional concerns; standard for removal/claims)
Musson Theatrical, Inc. v. Fed. Express Corp., 89 F.3d 1244 (6th Cir. 1996) (jurisdictional considerations and dismissal guidance)
Gamel v. City of Cincinnati, 625 F.3d 949 (6th Cir. 2010) (supplemental jurisdiction considerations when federal claims are dismissed)