Young v. MS Dept of Human Service
CourtCourt of Appeals for the Fifth Circuit
Date FiledNovember 4, 2026
Docket26-60714
StatusUnpublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
Case: 26-60714 Document: 23-1 Page: 1 Date Filed: 11/04/2026
United States Court of Appeals
for the Fifth Circuit United States Court of Appeals
____________ Fifth Circuit
FILED
No. 26-60714 November 4, 2026
Summary Calendar
Thomas B. Plunkett, III
____________ Clerk
Katie Young,
Plaintiff—Appellant,
versus
Mississippi Department of Human Services, (mdhs),
Defendant—Appellee.
______________________________
Appeal from the United States District Court
for the Northern District of Mississippi
USDC No. 4:26-CV-94
______________________________
Before Haynes, Graves, and Ramirez, Circuit Judges.
Per Curiam: *
Katie Young, proceeding pro se and in forma pauperis, brought claims
against the Mississippi Department of Human Services. The district court
dismissed her action as frivolous and for failure to state a plausible claim for
relief. As this was Young’s fifth case in two years to be dismissed as frivolous,
the district court also barred Young from further pro se in forma pauperis
_____________________
*
This opinion is not designated for publication. See 5th Cir. R. 47.5.
Case: 26-60714 Document: 23-1 Page: 2 Date Filed: 11/04/2026
No. 26-60714
filings without first obtaining permission from the chief district judge. We
affirm.
I. Background
Young applied for SNAP benefits on May 29, 2026. She alleges that
she received conflicting information from her case worker and a supervisor
regarding the paperwork required to file for benefits based on her disability.
Despite her purported confusion, Young was able to successfully submit her
SNAP application, and her benefits were added to her SNAP card on June
12, 2026.
Although she received her benefits, Young alleges that the conflicting
information she received caused her “emotional distress, lack of sleep, loss
of trust, etc.” She filed suit, proceeding pro se and in forma pauperis, alleging
violations of the Fourteenth Amendment, the Food and Nutrition Act of
2008, 7 U.S.C. § 2011, and the federal SNAP regulations at 7 C.F.R. Part
273.
The magistrate judge, in his Report and Recommendation,
recommended dismissal of her suit with prejudice under 28 U.S.C.
§ 1915(e)(2)(B) because the suit was frivolous and failed to state a plausible
claim for relief. Further, because this was Young’s fifth complaint to be
dismissed as frivolous over the last two years, the magistrate judge
recommended that Young be barred from filing any future pro se in forma
pauperis complaints without permission from the chief district judge of the
court. The district court adopted the Report and Recommendation in full.
Young then filed this timely appeal.
II. Jurisdiction & Standard of Review
This case was brought to the district court under 28 U.S.C. § 1331.
We have jurisdiction over this appeal under 28 U.S.C. § 1291.
2
Case: 26-60714 Document: 23-1 Page: 3 Date Filed: 11/04/2026
No. 26-60714
“We review a district court’s dismissal of an in forma pauperis
complaint as frivolous pursuant to 28 U.S.C. § 1915(e)(2)(B)(i) for an abuse
of discretion. A claim may be dismissed as frivolous if it does not have an
arguable basis in fact or law.” Brewster v. Dretke, 587 F.3d 764, 767 (5th Cir.
2009) (per curiam) (citation omitted). Further, “our review of a district
court’s sanctions against vexatious or harassing litigants is conducted under
the abuse of discretion standard.” Mendoza v. Lynaugh, 989 F.2d 191, 195 (5th
Cir. 1993).
III. Discussion
The district court did not abuse its discretion when it dismissed
Young’s complaint. While pro se pleadings are afforded liberal construction,
Young’s receipt of conflicting information about the paperwork required to
file for benefits does not constitute the basis for any sort of judicial relief.
Because any federal claim had no plausible foundation, Young failed to
establish federal question jurisdiction. See Arbaugh v. Y&H Corp., 546 U.S.
500, 513 n.10 (2006). Moreover, it is apparent that Young pleaded her best
case in her complaint. See Brewster, 587 F.3d at 767–68 (explaining that
granting leave to amend is not required under these circumstances); Ford v.
Guthrie, 101 F. App’x 978, 979 (5th Cir. 2004) (per curiam) (“The district
court does not err in dismissing a suit without providing an opportunity to
amend where, as here, no viable claim is perceptible from the underlying facts
asserted in the plaintiff’s pleadings.”). Accordingly, the district court
properly dismissed her claims as frivolous and for failure to state a claim.
Moreover, the district court did not abuse its discretion when it
sanctioned Young under Fed. R. Civ. P. 11. See Gelabert v. Lynaugh, 894
F.2d 746, 748 (5th Cir. 1990) (per curiam). This is Young’s fifth frivolous
complaint in two years. Young was also warned about the potential
consequences of filing further frivolous complaints in an earlier case. Young
3
Case: 26-60714 Document: 23-1 Page: 4 Date Filed: 11/04/2026
No. 26-60714
v. U.S. Dist. Ct. for N. Dist. of Miss., No. 4:25-CV-153-KHJ-MTP, 2025 WL
3229311, at *3 (N.D. Miss. Nov. 19, 2025); cf. Mendoza, 989 F.2d at 196
(concluding that the district court abused its discretion when it imposed a
similar sanction without prior warning). Therefore, because Young has
already filed five frivolous complaints and because she was on notice that she
may be sanctioned, the district court did not abuse its discretion when it
prohibited Young from filing further pro se in forma pauperis suits without
permission from the chief district judge. 1
IV. Conclusion
For the foregoing reasons, we AFFIRM.
_____________________
1
We do respect her statements about religion.
4