Barnett v. Kaufman

CourtDistrict Court, W.D. North Carolina
DecidedJanuary 21, 2025
Docket3:24-cv-00942
StatusUnknown

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

Bluebook
Barnett v. Kaufman, (W.D.N.C. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:24-cv-942-FDW

KEITH ANTONIO BARNETT, ) ) Plaintiff, ) ) vs. ) ) STEVEN R. KAUFMAN, et al., ) ORDER ) Defendants. ) ___________________________________ )

THIS MATTER is before the Court on initial review of the pro se Complaint. [Doc. 1]. The Plaintiff has paid the full filing fee. I. BACKGROUND The pro se Plaintiff filed this action pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 395-97 (1971)1 and the Federal Tort Claims Act (“FTCA”), in which he challenges the proceedings in criminal Case No. 3:18-cr-200-MOC-SCR- 1.2 The Plaintiff names as Defendants: Steven R. Kaufman, an Assistant U.S. Attorney; and Randolph M. Lee, Plaintiff’s criminal defense attorney. He appears to argue that: there is no proof of his guilt; Mr. Lee failed to tell Plaintiff about any pretrial hearings; and the Defendants never gave Plaintiff the opportunity to review discovery, including Brady material. [Doc. 1 at 3-5]. He seeks $12 million. [Id. at 6].

1 The Plaintiff cites 42 U.S.C. § 1983, which provides a cause of action for the deprivation of a plaintiff’s rights by a person acting under color of state law. However, the allegations address his federal criminal proceeding. The Court therefore liberally construes the Complaint as raising claims under Bivens, the judicially-created counterpart to § 1983 that allows an action for money damages to be brought against individuals acting under the color of federal law.

2 This case is largely duplicative of another pro se civil action filed by the Plaintiff in this Court, Case No. 3:24-cv- 943-FDW. It is unclear, at this juncture, whether these case should be permitted to proceed separately. II. STANDARD OF REVIEW A prisoner’s complaint seeking redress from the Government that is frivolous, malicious, or fails to state a claim may be dismissed sua sponte even if the Plaintiff has paid the full filing fee. 28 U.S.C. § 1915A. A complaint should not be dismissed for failure to state a claim “unless ‘after accepting all well-pleaded allegations in the plaintiff's complaint as true and drawing all

reasonable factual inferences from those facts in the plaintiff's favor, it appears certain that the plaintiff cannot prove any set of facts in support of his claim entitling him to relief.’” Veney v. Wyche, 293 F.3d 726, 730 (4th Cir. 2002) (quoting Edwards v. City of Goldsboro, 178 F.3d 231, 244 (4th Cir. 1999)). In its frivolity review, a court must determine whether the Complaint raises an indisputably meritless legal theory or is founded upon clearly baseless factual contentions, such as fantastic or delusional scenarios. Neitzke v. Williams, 490 U.S. 319, 327-28 (1989). A pro se complaint must be construed liberally. Haines v. Kerner, 404 U.S. 519, 520 (1972); see also Smith v. Smith, 589 F.3d 736, 738 (4th Cir. 2009) (“Liberal construction of the pleadings is particularly appropriate where … there is a pro se complaint raising civil rights

issues.”). However, the liberal construction requirement will not permit a district court to ignore a clear failure to allege facts in his complaint which set forth a claim that is cognizable under federal law. Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990). A pro se complaint must still contain sufficient facts “to raise a right to relief above the speculative level” and “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 570 (2007); see Ashcroft v. Iqbal, 556 U.S. 662 (2009) (the Twombly plausibility standard applies to all federal civil complaints including those filed under § 1983). This “plausibility standard requires a plaintiff to demonstrate more than a sheer possibility that a defendant has acted unlawfully.” Francis v. Giacomelli, 588 F.3d 186, 193 (4th Cir. 2009) (internal quotation marks omitted). He must articulate facts that, when accepted as true, demonstrate he has stated a claim entitling him to relief. Id. III. DISCUSSION A. Bivens Bivens allows an action for money damages to be brought against individuals acting under

the color of federal law for injuries caused by their unconstitutional conduct. Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 395-97 (1971). Bivens’ core premise is to deter individual officers’ unconstitutional acts. See Correctional Servs. Corp. v. Malesko, 534 U.S. 61 (2001). “Because vicarious liability is inapplicable to Bivens and § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.” Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009). Bivens claims are not actionable against the United States, federal agencies, or public officials acting in their official capacities. See FDIC v. Meyer, 510 U.S. 471, 475, 484-86 (1994); Dao v. Chao, 306 F.3d 170, 184 (4th Cir. 2002) (“a Bivens action does not lie against either agencies or

officials in their official capacity.”) (citing Meyer, 510 U.S. at 484-86). The Plaintiff appears to claim that Defendant Kaufman, a federal prosecutor, violated Plaintiff’s rights by inter alia prosecuting him without any evidence and by concealing discovery from him. “In Bivens-type actions …, prosecutors enjoy absolute immunity for conduct ‘intimately associated with the judicial phase of the criminal process.’” Lyles v. Sparks, 79 F.3d 372, 376 (4th Cir. 1996) (quoting Imbler v. Pachtman, 424 U.S. 409, 430 (1976)). The Plaintiff’s Bivens claim suggesting that Defendant Kaufman should not have prosecuted the Plaintiff and that he prevented the Plaintiff from seeing discovery are, therefore, dismissed. See Springmen v. Williams, 122 F.3d 211, 213 (4th Cir. 1997) (concluding that “[t]he doctrine of absolute immunity squarely covers a prosecutor’s decision to go forward with the prosecution”); Carter v. Burch, 34 F.3d 257, 262 (4th Cir.1994) (a prosecutorial decision to withhold exculpatory evidence was entitled to absolute immunity); see, e.g., Mixson v. Torres, No. CIVA 0:09-2454-MBS, 2010 WL 1791347, at *2 (D.S.C.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Correctional Services Corp. v. Malesko
534 U.S. 61 (Supreme Court, 2001)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
D.P. Muth J.P. Muth v. United States
1 F.3d 246 (Fourth Circuit, 1993)
Lyles v. Sparks
79 F.3d 372 (Fourth Circuit, 1996)
Ryle Edward Springmen v. Alexandra Williams
122 F.3d 211 (Fourth Circuit, 1997)
Francis v. Giacomelli
588 F.3d 186 (Fourth Circuit, 2009)
Smith v. Smith
589 F.3d 736 (Fourth Circuit, 2009)
Christopher Covey v. Assessor of Ohio County
777 F.3d 186 (Fourth Circuit, 2015)
Gravity Inc v. Microsoft Corp
309 F.3d 193 (Fourth Circuit, 2002)
Ahmed v. United States
30 F.3d 514 (Fourth Circuit, 1994)

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Bluebook (online)
Barnett v. Kaufman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnett-v-kaufman-ncwd-2025.