Hill v. Maplebear, Inc.

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SEAN MICHAEL HILL,
Plaintiff,
v.
MAPLEBEAR, INC.,
Defendant.
Case No. 26-cv-11069-AGT
SCREENING ORDER
Re: Dkt. No. 1
Having granted Sean Michael Hill’s in forma pauperis application, the undersigned
now screens Hill’s complaint under 28 U.S.C. § 1915(e)(2)(B) and concludes that the com-
plaint is deficient for the reasons identified below. Hill may amend the complaint to address
these deficiencies by October 30, 2026.
Defendant Maplebear, Inc. does business as Instacart, operating a platform that “fa-
cilitates same-day, on-demand grocery shopping and delivery.” Id. at ¶ 3. Hill alleges that
they began working as shopper for Instacart in October 2024, and that Instacart exercised
“detailed control” over their job performance. Id. at ¶¶ 13-14.1 Hill alleges that Instacart
didn’t reimburse them for expenses they incurred working for the platform, ensure they re-
ceived minimum wage, pay them overtime premiums, or provide them with “itemized wage
statements.” Id. at ¶¶ 17-20. Hill seeks to bring five claims alleging violations of the Cali-
fornia Unfair Competition Law (UCL), the Fair Labor Standards Act (FLSA), and the
1 Hill’s filings don’t use gendered pronouns. While Hill typically refers to themselves as “Hill” or “Plaintiff,” Hill
does self-refer as “themselves” in one instance. Dkt. 1 at ¶ 2. The Court adopts this usage.
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California Labor Code. Id. at ¶¶ 28-37.
Hill must plead these claims with greater detail. The Federal Rules of Civil Procedure
require that a plaintiff make “a short and plain statement of the claim showing that the
pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Hill’s complaint doesn’t currently meet
this standard. It contains only conclusory allegations that Hill wasn’t reimbursed for ex-
penses, wasn’t paid minimum wage, wasn’t paid at a premium for overtime work, and didn’t
receive itemized wage statements. Dkt. 1 at ¶¶ 17-20. Without any additional facts as to the
conduct and resulting harm underlying Hill’s causes of action, the Court can’t say whether
Hill states a plausible claim. Because Rule 8 also requires plaintiffs to cite specific legal
provisions, not just general bodies of law, Hill should also clarify what specific sections of
the FLSA and UCL are at issue in their first cause of action. Id. at ¶¶ 28-29.
Hill should also consider the Court’s subject matter jurisdiction in this case. Hill’s
complaint invokes both federal question and diversity jurisdiction. Dkt. 1 at ¶ 1.2 As to di-
versity jurisdiction, however, while Hill’s pleadings reasonably show diversity of citizen-
ship, they don’t suggest an amount in controversy exceeding $75,000. See 28 U.S.C. §
1332(a). And as to federal question jurisdiction, while claims involving the FLSA raise a
federal question, claims that are based solely in state law generally don’t. Dkt. 1 at ¶¶ 34-37.
Hill should explain why this court has supplemental jurisdiction over their state law claims
under 28 U.S.C. § 1367.
Finally, Hill should bear in mind that they can only bring claims that are personal to
themselves. Unrepresented parties can represent themselves in federal court, but that right is
“personal to the litigant and does not extend to other parties or entities.” Simon v. Hartford
2 Hill’s civil cover sheet asserts only diversity jurisdiction. Dkt. 1-1.
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Life, Inc., 546 F3d 661, 664 (9th Cir. 2008). As a result, the general rule is that unrepresented
parties can’t pursue claims on behalf of others in a representative capacity. Id. While none
of Hill’s claims explicitly refer to the collective action mechanism laid out in Section 216(b)
of the FLSA, other portions of the complaint cite 216(b), state Hill has “represented them-
selves and others,” refer broadly to “Instacart workers,” and appear to seek wide-ranging
injunctive and declaratory relief on behalf of those workers. Dkt. 1 at ¶¶ 2, 6. District courts
within the Ninth Circuit have rejected attempts by pro se plaintiffs to bring collective claims
under the FLSA. See Fabricius v. Dream.org, No. CV-26-00211-PHX-DJH, 2026 WL
1893698, at *1 (D. Ariz. July 1, 2026) (collecting cases). Hill should consider whether their
goals in this suit align with the remedies available to an individual, unrepresented plaintiff
under the FLSA. See 29 U.S.C. § 216. If Hill wishes to pursue a collective FLSA claim,
they’ll likely need to be represented by a lawyer. To the extent the relief they seek is avail-
able only through provisions of state law, such as the UCL, Hill should also consider whether
this Court can properly exercise jurisdiction over those state claims.
Hill may file an amended complaint on or before October 30, 2026. If they don’t do
so, or if they file an amended complaint that fails to state a claim for relief, the undersigned
will recommend that a district judge dismiss their case.
The Court refers Hill to the Northern District of California’s Legal Help Center,
where lawyers provide free basic legal assistance to those representing themselves in federal
court. Although Legal Help Center lawyers don’t represent parties, they can explain court
procedures, provide limited legal advice, and help prepare simple court filings. There are
two Legal Help Center locations: one is at the San Francisco courthouse at 450 Golden Gate
Avenue, and the other is at the Oakland courthouse at 1301 Clay Street. Plaintiff can
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schedule an appointment by calling 415-782-8982 or emailing FedPro@sfbar.org. Appoint-
ments are available in-person, by Zoom, or by telephone. Hill can find more information at
https://cand.uscourts.gov/representing-yourself/free-legal-help-people-without-lawyers.
The Court also has a free guide, “Representing Yourself in Federal Court: A Hand-
book for Pro Se Litigants,” which provides instructions on how to proceed at every stage of
a case. Hill can access it online (https://cand.uscourts.gov/representing-yourself/pro-se-
handbook) or in hard copy free of charge from the Clerk’s Office.
IT IS SO ORDERED.
Dated: October 16, 2026
______________________________
Alex G. Tse
United States Magistrate Judge
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