The Third Circuit Court of Appeals affirmed the dismissal of a pro se lawsuit challenging child support enforcement actions and credit reporting practices in *Williams v. Philadelphia Child Support Court*. The court issued a brief per curiam opinion on Jan. 6, 2026, upholding the U.S. District Court for the Eastern District of Pennsylvania's decision to dismiss the case under 28 U.S.C. § 1915(e)(2)(B)(ii).
William Williams, representing himself and proceeding in forma pauperis, had sued multiple defendants including the Philadelphia Child Support Family Court Division, Delaware's child support court division, the City of Philadelphia, and three major credit reporting agencies: Equifax, TransUnion, and Experian. Williams alleged violations of constitutional rights and the Fair Credit Reporting Act.
According to the Third Circuit's opinion, Williams claimed that between 2009 and 2013, family courts in Philadelphia County and Delaware imposed child support obligations that led to negative consequences including wage garnishment and incarceration when he failed to comply. The opinion indicates Williams contended that any attempt to collect child support from him was illegitimate because he never consented to the obligations.
The case was originally filed in district court as Civil Action No. 2:24-cv-06020 before District Judge Karen S. Marston, who dismissed the complaint under the federal statute that allows courts to dismiss frivolous or legally insufficient claims from litigants proceeding in forma pauperis. This provision, codified at 28 U.S.C. § 1915(e)(2)(B)(ii), gives federal courts authority to screen and dismiss cases that fail to state a claim upon which relief can be granted.
The Third Circuit panel, consisting of Circuit Judges Stephanos Bibas, Cindy Chung, and L. Felipe Restrepo, issued a non-precedential per curiam opinion affirming the district court's judgment. The case was submitted under Third Circuit Local Appellate Rule 34.1(a), which allows for submission without oral argument when the court determines the case can be decided on the briefs alone.
The dismissal under Section 1915(e)(2)(B)(ii) represents one of several screening mechanisms federal courts use to manage cases filed by pro se litigants proceeding without payment of filing fees. Congress enacted these provisions to prevent abuse of the federal court system while still preserving access to justice for indigent litigants with meritorious claims.
Child support enforcement involves complex interactions between state family courts, federal agencies, and private credit reporting companies. Courts routinely enforce child support orders through various mechanisms including wage garnishment, asset seizure, and in some cases, contempt proceedings that can result in incarceration. Credit reporting agencies often receive information about unpaid child support obligations, which can affect an individual's credit score and access to financial services.
The Fair Credit Reporting Act, which Williams cited in his complaint, regulates how credit reporting agencies collect, maintain, and distribute consumer credit information. The law provides certain rights to consumers regarding the accuracy of their credit reports and includes procedures for disputing incorrect information.
Williams' apparent argument that he never consented to child support obligations reflects a common but legally unfounded position in family law disputes. Child support obligations typically arise from court determinations of parental responsibility and are not based on voluntary agreements, though parents can enter into consent agreements that courts may adopt as orders.
The Third Circuit's affirmance suggests the district court properly determined that Williams' claims either failed to state a valid legal theory or were otherwise legally insufficient. The court's decision to issue a non-precedential opinion indicates the panel viewed this as a straightforward application of existing law rather than a case requiring detailed legal analysis or guidance for future cases.
Pro se litigation presents ongoing challenges for federal courts, which must balance access to justice concerns with the need to manage frivolous cases effectively. The screening provisions in Section 1915 allow courts to dismiss legally insufficient cases early in the process, conserving judicial resources while still providing meaningful review of claims.
The case demonstrates how federal courts handle challenges to state court proceedings and administrative actions. While federal courts have limited jurisdiction to review state family court decisions, they can hear claims alleging constitutional violations or violations of federal statutes like the Fair Credit Reporting Act.
Williams' case appears to be concluded with the Third Circuit's affirmance, though the opinion text suggests there may have been additional details in the lower court proceedings that were not fully outlined in the appeals court's brief ruling. The dismissal under the frivolous litigation statute indicates the federal courts found Williams' legal theories insufficient to proceed, regardless of the underlying factual disputes about his child support obligations.