Armstead v. Baldwin

District Court, S.D. Ohio·Decided September 23, 2025·No. 2:24-cv-04110·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

DEMARCO ARMSTEAD, : Case No. 2:24-cv-4110 : Plaintiff, : : District Judge Algenon L. Marbley vs. : Magistrate Judge Elizabeth P. Deavers : SHERIFF BALDWIN, et al., : : Defendants. : : ORDER AND REPORT AND RECOMMENDATION

Plaintiff, a former pretrial detainee at the James A. Karnes Corrections Center, has filed a civil rights complaint in this Court. After filing his initial complaint, Plaintiff has submitted ten documents seeking to amend or supplement his complaint. (see Docs. 3, 7, 9, 10, 12, 14, 15, 17, 23, 25). In response to plaintiff’s motions the undersigned provided plaintiff with a final opportunity to file a single amended complaint. (Doc. 18). As noted in the Order, plaintiff’s factual allegations at that point in the proceedings spanned eight different documents, eighty-four pages, and appeared to concern separate and distinct transactions and occurrences. (See id.). In response, plaintiff filed a final motion to amend his complaint (Doc. 23), which was granted, as well as a motion to convert many of his prior motions to amend or supplement to affidavits (Doc. 22), which remains pending. This matter is now before the Court for a sua sponte review of the amended complaint1 (Doc. 25) 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 28 U.S.C. § 1915(e)(2)(B). As discussed below, despite being advised that under Fed. R. Civ. P. 20(a) the claims

asserted in his amended complaint must arise out of the same transaction or occurrence (see Doc. 8 at PageID 119, Doc. 18 at PageID 241), plaintiff’s amended complaint summarizes the majority, if not all, of the claims presented in his various motions to amend. (See Doc. 25). In light of the below recommendation that many of plaintiff’s unrelated claims be dismissed without prejudice, plaintiff’s “Motion to convert Documents #1, #3, #7, #10, #12, and #14 to Affidavits” (Doc. 22) is DENIED. Screening of Plaintiff’s Amended Complaint A. Legal Standard In enacting the original in forma pauperis statute, 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.” Denton v. Hernandez, 504 U.S. 25, 31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To prevent such abusive litigation, Congress has authorized federal courts to dismiss an in forma pauperis complaint if they are satisfied that the action is frivolous or malicious. Id.; see also 28 U.S.C. §§ 1915(e)(2)(B)(i). A complaint may be dismissed as frivolous when the plaintiff cannot

1 The amended complaint (Doc. 25) supersedes the original complaint and serves as the operative complaint in this action. See Fed. R. Civ. P. 15(a)(2). See Calhoun v. Bergh, 769 F.3d 409, 410 (6th Cir. 2014) (“An amended complaint supersedes and earlier complaint for all purposes.”) (quotation and citation omitted).

2 make any claim with a rational or arguable basis in fact or law. Neitzke v. Williams, 490 U.S. 319, 328-29 (1989); see also Lawler v. Marshall, 898 F.2d 1196, 1198 (6th Cir. 1990). An action has no arguable legal basis when the defendant is immune from suit or when plaintiff claims a violation of a legal interest which clearly does not exist. Neitzke, 490 U.S. at 327. An action has no arguable factual basis when the allegations are delusional or rise to the level of the irrational or

“wholly incredible.” Denton, 504 U.S. at 32; Lawler, 898 F.2d at 1199. The Court need not accept as true factual allegations that are “fantastic or delusional” in reviewing a complaint for frivolousness. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (quoting Neitzke, 490 U.S. at 328). Congress also has authorized the sua sponte dismissal of complaints that fail to state a claim upon which relief may be granted. 28 U.S.C. §§ 1915 (e)(2)(B)(ii). A complaint filed by a pro se plaintiff must be “liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). By the same token, however, the complaint “must

contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Hill, 630 F.3d at 470-71 (“dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim” under §§ 1915A(b)(1) and 1915(e)(2)(B)(ii)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). The Court must accept all well-pleaded

3 factual allegations as true, but need not “accept as true a legal conclusion couched as a factual allegation.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). Although a complaint need not contain “detailed factual allegations,” it must provide “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). A pleading that offers “labels and conclusions” or “a formulaic

recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. The complaint must “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Erickson, 551 U.S. at 93 (citations omitted). A. Allegations in the Complaint Plaintiff brings this action under 42 U.S.C. § 1983, the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act of 1973. (See Doc. 25 at PageID 256). As defendants, plaintiff names Sheriff Dallas Baldwin, Commissioner Kevin Boyce, Dep. Hicks, Armor Health of Ohio, Armor Correctional Health Services Inc., Nurse Jane and John Doe, Dr.

Abdi, Dep. Lilly, Sgt. Collier, Dep. Matt Blake, Sgt. Zack Lewis, Sgt.

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