Santiago-Ramirez v. Brook Brothers Garment Manufacturing
1:25-cv-00608
| D. Del. | Jun 27, 2025Background
- Plaintiff Gloria Maria Montoya Santiago-Ramirez, proceeding pro se, filed a civil action against several companies including Brooks Brothers Garment Manufacturing and others.
- Plaintiff alleges broadly that she is unemployed, has zero income, and wishes to return to work, but provides no clear connection between herself and the defendant companies.
- The Complaint is unclear regarding the harm suffered, the nature of injuries, and the specific relief sought.
- Supporting documents submitted are mostly unrelated business cards, identification, and financial information, not directly supporting any legal claim.
- Plaintiff was allowed to proceed in forma pauperis, triggering the court’s duty to screen her complaint for merit under 28 U.S.C. § 1915(e).
- The Complaint follows a pattern of several similar, meritless filings by Plaintiff against various unrelated parties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction | Claim presents a federal question; seeks relief from defendants | No jurisdiction; Complaint lacks federal question | No subject matter jurisdiction; case dismissed. |
| Sufficiency of Complaint | (Unclear/No coherent argument presented) | Complaint is vague and unsupported by facts | Fails to state a plausible claim; dismissed as frivolous |
| Request for Employment | Implied demand for job/employment benefit from defendants | Not within court's power; no valid discrimination claim alleged | Court cannot grant employment without proper claims |
| Prior Litigation Patterns | (No argument) | Pattern of similar meritless filings | Complaint deemed frivolous due to pattern and content |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints must be held to less stringent pleading standards)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (a complaint must have well-pleaded factual allegations to state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (a complaint requires more than labels and conclusions to survive dismissal)
- Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (court must accept all factual allegations as true and construe in plaintiff's favor in pro se cases)
- Johnson v. City of Shelby, 574 U.S. 10 (2014) (a complaint may not be dismissed for imperfect legal theory statements)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)