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