Where a pro se plaintiff purported to file a complaint under the False Claims Act, but the allegations were about a dispute with her neighbor, a plaintiff cannot proceed with a qui tam action on a pro se basis and each of the claims failed as a matter of law, the complaint was dismissed with prejudice.

Background

Joelle Angel, appearing pro se, submitted an application to proceed without prepaying fees or costs, along with a proposed complaint. The proposed complaint identifies the named plaintiff as “United States ex rel. Joelle Angel” and characterizes this lawsuit as a qui tam action that asserts claims pursuant to the False Claims Act, or FCA, and other laws.

Shortly after filing this action, Ms. Angel submitted a proposed first amended complaint, and the United States filed a proposed “Motion to Terminate United States as a Plaintiff and Unseal the Case.” Thereafter, Ms. Angel filed a proposed “Motion for ‘Extended’ Time to Serve Complaint,” a proposed motion to amend and a proposed second amended complaint, or SAC.

IFP

Based on the financial information contained in the application, the court is satisfied that Ms. Angel qualifies for in forma pauperis status. Accordingly, that application is granted.

Plausibility

When a plaintiff is granted authorization to proceed in forma pauperis, the court is obligated to screen the operative complaint to determine, among other things, whether the complaint states a claim on which relief may be granted. In deference to Ms. Angel’...

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