Elam v. Snapchat, Inc.

[3] 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA [6] 7 ERIC JORDAN ELAM, 1001453590, Case No. 25-cv-03827-CRB (PR) 8 Plaintiff, ORDER OF DISMISSAL 9 v. 10 SNAPCHAT, INC., et al., 11 Defendant(s). 12 I. 13 Plaintiff, a prisoner at Dooly State Prison in Unadilla, Georgia, has filed a pro se complaint 14 alleging that Snapchat, Inc., Meta Platforms, Inc., and Verizon Wireless violated the Stored 15 Communications Act (SCA), 18 U.S.C. §§ 2701-2713 , when they disclosed his electronic 16 communications to law enforcement pursuant to a search warrant issued in March 2021 by 17 Cherokee County Magistrate Court. Plaintiff argues that the Cherokee County Magistrate Court 18 does not qualify as a “court of competent jurisdiction” under § 2703(a) because it lacks general criminal jurisdiction as required by federal law. [19] Plaintiff seeks damages and declaratory relief, and also leave to proceed in forma pauperis [20] (IFP) under 28 U.S.C. § 1915 . [21] II. [22] A federal court shall dismiss a case filed IFP at any time if it determines that the action is [23] “frivolous or malicious,” “fails to state a claim on which relief may be granted” or “seeks [24] monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915 (e)(2). [25] III. [26] The SCA provides that “court of competent jurisdiction” includes “a court of general [27] ] U.S.C. § 2711. Georgia magistrate courts are courts of limited jurisdiction, in that among other 2 || things they do not have power to issue process in the nature of mandamus, prohibition, specific 3 || performance, quo warranto, and injunction. Ga. Const. art. VI, § 1, 991, 1V. But Georgia law 4 || specifically provides that Georgia magistrate courts may issue warrants. See Ga. Code § 17-4-40 5 (“[a]ny judge of a superior, city, state, or magistrate court or any municipal officer clothed by law 6 || with the powers of a magistrate may issue a warrant for the arrest of any offender . . .”); Ga. Code 7 § 15-10-2(a)(1) (“Each magistrate court and each magistrate thereof shall have jurisdiction and 8 || power over the following matters: (1) The hearing of applications for and the issuance of arrest 9 || and search warrants ...”). 10 To be a court of competent jurisdiction within the meaning of § 2711 requires that the 11 court have the authority to issue warrants. See Hubbard v. MySpace, Inc., 788 F. Supp. 2d 319 , 12 || 324(S.D.N.Y. 2011) (in context of SCA, court of competent jurisdiction “implicates a judicial 13 officer’s authority to issue warrants, not to try cases; holding that warrant issued by Cherokee 14 || County magistrate court was not invalid due to fact issuing magistrate could not have presided 3 15 over criminal trial of user). The Cherokee County Magistrate Court is a court of competent 16 || jurisdiction within the meaning of § 2711 because it is authorized to issue warrants. See id. i 17 || Plaintiffs allegations therefore fail to state a claim for violation of the SCA. 18 IV. 19 For the foregoing reasons, the complaint is DISMISSED under 28 U.S.C. § 1915 (e)(2) for 20 || failure to state a claim on which relief may be granted. 21 The clerk shall close the case and terminate all pending motions as moot. 22 IT IS SO ORDERED. 23 || Dated: June 4, 2025 24 Lo 5 — CHARLES R. BREYER 25 United States District Judge