Anderson v. Conley

CourtDistrict Court, S.D. Ohio
DecidedMarch 18, 2025
Docket1:24-cv-00700
StatusUnknown

This text of Anderson v. Conley (Anderson v. Conley) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Conley, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

DAVID M. ANDERSON, : Case No. 1:24-cv-700 : Plaintiff, : : District Judge Matthew W. McFarland vs. : Magistrate Judge Peter B. Silvain, Jr. : DAVID CONLEY, et al., : : Defendants. : :

REPORT AND RECOMMENDATION1

Plaintiff, a prisoner at the Southern Ohio Correctional Facility, has filed a pro se civil rights complaint against Defendants David Conley and Officer Fore. (See Doc. 1-1, Complaint at PageID 12). By separate Order Plaintiff has been granted leave to proceed in forma pauperis. On December 13, 2024, the Court issued an Order providing Plaintiff with the opportunity to file an Amended Complaint. (Doc. 2). As noted in the Order, Plaintiff’s Complaint appears to be incomplete, including a blank “Statement of Claims” page. (See Doc. 1-1, Complaint at PageID 15). Noting that the Complaint otherwise failed to state with particularity what any named Defendant did or failed to do in violation Plaintiff’s rights, the Court provided Plaintiff with thirty days to file an Amended Complaint. The Order further specified that should Plaintiff fail to file an Amended Complaint, the Court would proceed with the initial screen of the Complaint as submitted. (See Doc. 2, at PageID 61). To date, more than thirty days after the December 13, 2024 Order, Plaintiff has not responded to the Order.

1 Attached is a NOTICE to the parties regarding objections to the Report and Recommendation. Accordingly, this matter is before the Court for a sua sponte review of the Complaint to determine whether the Complaint, or any portion of it, should be dismissed because it is frivolous, malicious, fails to state a claim upon which relief may be granted or seeks monetary relief from a Defendant who is immune from such relief. See Prison Litigation Reform Act of 1995 § 804, 28 U.S.C. § 1915(e)(2)(B); § 805, 28 U.S.C. § 1915A(b).

Screening of Plaintiff’s Complaint A. Legal Standard Congress enacted 28 U.S.C. § 1915, the federal in forma pauperis statute, seeking to “lower judicial access barriers to the indigent.” Denton v. Hernandez, 504 U.S. 25, 31 (1992). In doing so, however, “Congress recognized that ‘a litigant whose filing fees and court costs are assumed by the public, unlike a paying litigant, lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits.’” Id. at 31 (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To address this concern, Congress included subsection (e)(2)2 as part of the statute, which provides in pertinent part:

(2) Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that—

* * *

(B) the action or appeal—

(i) is frivolous or malicious;

(ii) fails to state a claim on which relief may be granted; or

(iii) seeks monetary relief against a defendant who is immune from such relief.

28 U.S.C. § 1915(e)(2)(B); Denton, 504 U.S. at 31. See also § 1915A(b). Thus, § 1915(e) requires sua sponte dismissal of an action upon the Court’s determination that the action is frivolous or

2 Formerly 28 U.S.C. § 1915(d). malicious, or upon determination that the action fails to state a claim upon which relief may be granted. To properly state a claim upon which relief may be granted, a plaintiff must satisfy the basic federal pleading requirements set forth in Federal Rule of Civil Procedure 8(a). See also Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (applying Federal Rule of Civil Procedure

12(b)(6) standards to review under 28 U.S.C. §§ 1915A and 1915(e)(2)(B)(ii)). Under Rule 8(a)(2), a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Thus, Rule 8(a) “imposes legal and factual demands on the authors of complaints.” 16630 Southfield Ltd., P’Ship v. Flagstar Bank, F.S.B., 727 F.3d 502, 503 (6th Cir. 2013). Although this pleading standard does not require “‘detailed factual allegations,’ . . . [a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action’” is insufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). A complaint will not “suffice if it tenders ‘naked

assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557). Instead, to survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a complaint must contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). Facial plausibility is established “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “The plausibility of an inference depends on a host of considerations, including common sense and the strength of competing explanations for the defendant’s conduct.” Flagstar Bank, 727 F.3d at 504 (citations omitted). Further, the Court holds pro se complaints “‘to less stringent standards than formal pleadings drafted by lawyers.’” Garrett v. Belmont Cnty. Sheriff’s Dep’t., No. 08-3978, 2010 WL 1252923, at *2 (6th Cir. April 1, 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). This lenient treatment, however, has limits; “‘courts should not have to guess at the nature of the claim asserted.’” Frengler v. Gen. Motors, 482 F. App’x 975, 976–77 (6th Cir. 2012) (quoting Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989)).

B. Allegations in the Complaint Without factual elaboration, Plaintiff alleges that Defendants were deliberately indifferent to his serious medical needs. (Doc. 1-1, Complaint at PageID 13). Aside from this conclusory allegation, Plaintiff’s sole allegation against Defendant Conley is that he is employed by the Ohio Department of Rehabilitation and Corrections (ODRC) as the Advanced Level Provider/Nurse Practitioner. (Id.). As to Defendant Officer Fore, Plaintiff also alleges that he is employed by the ODRC and that Fore “was working as housing unit booth officer, operating the electronic crossover crash gates while on his cell phone.” (Id.).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Neil Frengler v. General Motors
482 F. App'x 975 (Sixth Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Warren v. Doe
28 F. App'x 463 (Sixth Circuit, 2002)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)

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Anderson v. Conley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-conley-ohsd-2025.