Adam Moses Dellea v. William G. Prummell, Jr. et al.

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

ADAM MOSES DELLEA,

Plaintiff,

v. Case No.: 2:26-cv-841-SPC-DNF

WILLIAM G. PRUMMELL, JR. et al.,

Defendants. / OPINION AND ORDER Before the Court is Plaintiff Adam Moses Dellea’s Complaint (Doc. 1). Dellea states he is a civilly committed detainee in the County Jail, and he sues three jail officials under 42 U.S.C. § 1983. The Court granted Dellea leave to proceed in forma pauperis, so the Court must review the complaint to determine if it is frivolous or malicious, fails to state a claim, or seeks monetary damages from anyone immune from such relief. See 28 U.S.C. § 1915(e)(2). Federal Rule of Civil Procedure 12(b)(6) provides the standard for screening complaints under § 1915. Mitchell v. Farcass, 112 F.3d 1483, 1485 (11th Cir. 1997). A district court should dismiss a claim when a party does not plead facts that make the claim facially plausible. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible when a court can draw a reasonable inference, based on facts pled, that the opposing party is liable for the alleged misconduct. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). This plausibility standard requires “more than a sheer possibility that

a defendant has acted unlawfully.” Id. (citing Twombly, 550 U.S. at 557 (internal quotation marks omitted)). And a plaintiff must allege more than labels and conclusions amounting to a formulaic recitation of the elements of a cause of action. Twombly, 550 U.S. at 555.

To state a § 1983 claim, a plaintiff must allege that (1) the defendant deprived him of a right secured under the Constitution or federal law, and (2) the deprivation occurred under color of state law. Bingham v. Thomas, 654 F.3d 1171, 1175 (11th Cir. 2011) (citing Arrington v. Cobb Cnty., 139 F.3d 865,

872 (11th Cir. 1998)). In addition, a plaintiff must allege and establish an affirmative causal connection between the defendant’s conduct and the constitutional deprivation. Marsh v. Butler Cnty., Ala., 268 F.3d 1014, 1059 (11th Cir. 2001).

Dellea alleges he requested a form petition for a writ of habeas corpus from jail officials, and defendant Davies told him to use the law library on his facility-provided tablet. Dellea complains the tablet does not contain editable forms, so the defendants deprived him of a legal form he needed. He seeks

$10,000 in damages from each defendant and injunctive relief. State officials may not obstruct a detainee’s access to the courts. Wright v. Newsome, 795 F.2d 964, 968 (11th Cir. 1986). To state an access-to-the- courts claim, a detainee must show actual injury—i.e., that the defendant’s conduct “hindered his efforts to pursue a legal claim.” Lewis v. Casey, 518 U.S.

343, 351 (1996). As the Supreme Court explained in Lewis, “an inmate cannot establish relevant actual injury simply by establishing that his prison’s law library or legal assistance program is subpar in some theoretical sense.” 518 U.S. at 351. A plaintiff “must go one step further and demonstrate that the

alleged shortcomings in the library or legal assistance program hindered his efforts to pursue a legal claim.” Id. And “the injury requirement is not satisfied by just any type of frustrated legal claim.” Id. at 354. A plaintiff must show that officials “hindered his efforts to proceed with a legal claim in a criminal

appeal, postconviction matter, or civil rights action seeking to vindicate basic constitutional rights.” Wilson v. Blankenship, 163 F.3d 1284, 1291 (11th Cir. 1998) (internal quotation marks and citation omitted). Dellea fails to state an access-to-court claim because he does not identify

a nonfrivolous claim or defense hindered by jail officials. His vague allegation that he did not receive a form he needed is not enough, particularly since Dellea can obtain forms from the clerk of this Court. See M.D. Fla. 6.04(a) (“A pro se person in custody must use the standard form – available without charge from

the clerk and on the court’s website – to file” complaints and habeas petitions). The Court will dismiss Dellea’s complaint for failure to state a claim. And because Dellea cannot establish harm stemming from the jail’s failure to provide a form Dellea can get for free elsewhere, he cannot save this action with an amendment. The Court thus finds amendment futile and will close this case. Accordingly, it is ORDERED: Adam Moses Dellea’s Complaint (Doc. 1) is DISMISSED without prejudice. The Clerk is DIRECTED to send Dellea a § 2241 habeas form, terminate pending motions and deadlines, enter judgment, and close this case. DONE and ORDERED in Fort Myers, Florida on April 7, 2026.

UNITED STATES DISTRICT JUDGE SA: FTMP-1 Copies: All Parties of Record