Zhongxiao Michael Chen v. Michigan State University

Whether a civil action is “commenced” under Federal Rule of Civil Procedure 3 when a complaint is electronically delivered and date-stamped by the court’s filing system or only when the filing fee is paid or leave to proceed in forma pauperis is granted—an issue that has created a circuit split and affects thousands of cases each year.

Whether the district court’s dismissal of an employment discrimination complaint for failure to plead a prima facie case under Rule 12(b)(6) conflicts with Rule 8 and this Court’s decision in Swierkiewicz v. Sorema N. A., 534 U.S. 506 (2002), particularly where the Sixth Circuit declined to consider the issue. RELATED PROCEEDINGS Chen v. Michigan State University, No. 1:24-cv-254 (W.D. Mich.), judgment entered Nov. 20, 2024. Chen v. Michigan State University, No. 24-2076 (6th Cir.), judgment entered Aug. 13, 2025. There are no other proceedings in any court that are directly related to this case.