Page v. Juhola, 2:17-cv-00644

Pro se plaintiff Ellen Page filed suit in the Southern District of Ohio against Michael Juhola and sought leave to proceed in forma pauperis (IFP).
Plaintiff's one-page complaint alleged that Juhola colluded to obtain medical opinions, engineered guardianship proceedings, and enabled theft of her assets, leaving her bankrupt; allegations were rambling and partially illegible.
Plaintiff sought a court order to secure all of Defendant’s money for her recovery.
The magistrate judge granted Page's IFP request but performed the mandatory initial screening under 28 U.S.C. § 1915(e)(2).
The magistrate concluded the complaint contained no plausible legal claim, describing the allegations as "clearly irrational" and recommended dismissal as frivolous.
The report notified the parties of the 14-day period to file objections, explained de novo review by a district judge, and warned that failure to object waives appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IFP should be granted	Page asserted inability to pay court costs and sought IFP	No opposition recorded	IFP granted under 28 U.S.C. § 1915(a)
Whether the complaint states a non-frivolous claim under § 1915(e)(2)	Page alleged guardian- and probate-related misconduct by Juhola causing loss of funds	Implicit defense: allegations insufficient and not plausibly tied to legal claims	Complaint dismissed as frivolous; allegations "clearly irrational" and not facially plausible
Whether plaintiff must be afforded de novo review opportunities	Page did not specifically request further procedure in the report	Court followed standard objection procedure	Report recommended dismissal but advised 14-day objection period and explained de novo review on proper objections

Neitzke v. Williams, 490 U.S. 319 (1989) (a frivolous claim lacks an arguable basis in law or fact)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must contain enough facts to state a claim that is plausible on its face)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading; courts may reject "conclusory" or "wholly incredible" allegations)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings are construed liberally)
Wells v. Brown, 891 F.2d 591 (6th Cir. 1989) ("basic pleading essentials" required even for pro se litigants)
Ruiz v. Hofbauer, [citation="325 F. App'x 427"] (6th Cir. 2009) (courts need not accept allegations that are clearly irrational or incredible)
Thomas v. Arn, 474 U.S. 140 (1985) (failure to object to a magistrate judge's report may waive de novo review)
United States v. Walters, 638 F.2d 947 (6th Cir. 1981) (same waiver principle for failure to timely object to magistrate recommendations)