California Case Summaries

Matteo v. National Railroad Passenger Corp. — Indigent plaintiff clears initial screening and may serve Amtrak

Unreported / Non-Citable

Case
Matteo v. National Railroad Passenger Corp.
Court
U.S. District Court — Southern District of California
Judge
Ruth Bermudez Montenegro (Joseph R. Biden Jr., 2022)
Date Decided
2026-10-13
Docket No.
3:25-cv-03532
Status
Unreported
Topics
Civil Procedure, In Forma Pauperis, Americans with Disabilities Act, FOIA, Pro Se Litigation, Screening Under 28 U.S.C. § 1915(e)

Background

Pro se plaintiff Carolyn Grace Matteo filed a complaint on December 11, 2025, against Amtrak and its Chief Legal Officer William Herrmann. Matteo alleges that on August 23, 2025, she boarded an Amtrak train in Philadelphia with a fractured ankle, disclosed her disability, and requested reasonable accommodation for leg elevation. The conductor denied her request, threatened to remove her from the train, and filed a false Passenger Incident Report claiming she was removed for improper conduct.

Matteo further alleges Amtrak erased her app travel history and upcoming trips, and that she experienced a series of negative interactions when attempting to file complaints and request records through FOIA. Her complaint asserts five causes of action: ADA retaliation, fraud/falsification of records, intentional infliction of emotional distress, evidence tampering under 44 U.S.C. § 3106, and FOIA violations. Matteo filed an application to proceed in forma pauperis (IFP), attesting to monthly income of $910, a negative checking account balance, an old car as her only asset, and monthly expenses of $1,475.

The Court’s Holding

The court granted Matteo’s IFP motion. It found she adequately demonstrated indigence under 28 U.S.C. § 1915(a) and S.D. Cal. Civ.

R. 3.2(a), as she cannot pay the $405 filing fee and still afford the necessities of life. The court also conducted mandatory screening under 28 U.S.C. § 1915(e)(2)(B) and determined the complaint is not frivolous or malicious, does not seek monetary relief from immune defendants, and states plausible claims for relief under the Rule 12(b)(6) standard. The court liberally construed the pro se pleading and found federal question jurisdiction under 28 U.S.C. § 1331 for the ADA and FOIA claims, with supplemental jurisdiction under 28 U.S.C. § 1367 over the state law claims. The clerk is directed to issue summons and provide an IFP package for service by the U.S. Marshals Service.

Key Takeaways

  • Plaintiff’s IFP application granted based on monthly income of $910, negative checking account balance, and expenses exceeding income.
  • Complaint survives § 1915(e)(2)(B) screening: states plausible ADA retaliation, FOIA, fraud, intentional infliction of emotional distress, and evidence tampering claims.
  • Federal question jurisdiction exists for ADA and FOIA claims; supplemental jurisdiction covers state law claims.
  • Court’s screening is not a substitute for future Rule 12(b)(6) motions or motions to compel arbitration by defendants.
  • U.S. Marshals Service ordered to serve defendants at government expense; defendants must respond per Rule 12(a) once served.

Why It Matters

This order allows a pro se disability rights case against Amtrak to proceed without prepayment of fees. The court’s screening analysis confirms that Matteo’s allegations—including denial of accommodation for a fractured ankle, falsification of an incident report, deletion of travel records, and FOIA non-responsiveness—collectively state plausible federal and state claims at the pleading stage. The ruling preserves all five causes of action for further litigation and notes that defendants remain free to challenge the complaint via Rule 12(b)(6) or seek to compel arbitration based on Amtrak’s terms of service.

The case will now proceed to service and responsive pleadings. The ruling is case-specific and should be read with its procedural posture and, where applicable, its nonprecedential status in mind. The result is narrowly framed. Practitioners should distinguish the court’s actual disposition from issues it mentioned but expressly left unresolved.

Read the full opinion (PDF) · Court docket

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