Braunskill v. Smith

CourtDistrict Court, S.D. Ohio
DecidedMay 13, 2025
Docket1:24-cv-00140
StatusUnknown

This text of Braunskill v. Smith (Braunskill v. Smith) 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
Braunskill v. Smith, (S.D. Ohio 2025).

Opinion

SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

RALPHIELL BRAUNSKILL, Case No. 1:24-cv-140

Plaintiff, McFarland, J. Bowman, M.J. v.

AGENT DANIELLE SMITH, et al.,

Defendants.

REPORT AND RECOMMENDATION On March 18, 2024, Plaintiff initiated this pro se prisoner civil rights action pursuant to 42 U.S.C. § 1983. The case is presently before the undersigned on Defendants’ motion to dismiss. For the reasons that follow, the undersigned recommends that Defendants’ motion to dismiss be DENIED, but that the claims in the amended complaint be DISMISSED sua sponte under the PLRA. I. Background On June 11, 2024, the undersigned filed a Report and Recommendation (“R&R”) that recommended the sua sponte dismissal of most claims and defendants on initial screening under provisions of the Prison Litigation Reform Act of 1995 (“PLRA”). See 28 U.S.C. § 1915(e)(2)(B); 28 U.S.C. § 1915A(b). The same R&R recommended that a single Fourth Amendment claim against Defendants Smith and Taylor in their individual capacities be permitted to proceed for further factual development.1 In the latter claim,

1The original R&R noted that the sua sponte recommendation on initial screening did not foreclose the possibility that Plaintiff’s claims might still be subject to dismissal based on “the applicable statute of agents Smith and Taylor subjected him to prolonged detention without probable cause by their “refusal to comply with the demand for 48 hour probable cause demand in accordance with the 4th amendment” after Plaintiff’s arrest.” (Doc. 3 at PageID 39, 41). Plaintiff further alleged that the defendants improperly obtained “acquisition of the lab report during plaintiff’s unlawful arrest, which subsequently led to plaintiff’s indictment & conviction, which under ordinary circumstances would have been excluded.” (Id.) The presiding district judge adopted the R&R as the opinion of the Court, overruling two sets of objections filed by Plaintiff. (Doc. 9). Plaintiff appealed the dismissal to the Sixth Circuit, which dismissed for lack of appellate jurisdiction. Braunskill v. Smith, No.

24-3916, 2024 WL 5344454 (Dec. 12, 2024). On August 12, 2024, Plaintiff filed an “Amended Complaint.” (Doc. 7). Because Plaintiff filed his amended complaint shortly before the Court’s sua sponte dismissal of most of the claims in his original complaint, the amended complaint has yet to be screened under the PLRA. After the Court’s dismissal of all claims and Defendants except for Defendants Smith and Taylor, service of the original complaint was executed on those two Defendants alone. On September 26, 2024, Defendants Smith and Taylor moved to dismiss. (Doc. 12). Plaintiff filed a response in opposition to Defendants’ motion, to which Defendants filed a reply. (Docs. 16, 17).

II. Analysis A. Defendants’ Motion to Dismiss Defendant’s motion to dismiss is based solely on a statute of limitations defense, and references the allegations of both Plaintiff’s original and amended complaints. In both violation of the Fourth Amendment occurred from February 26, 2022 through March 10, 2022. Because the elements of false imprisonment and false arrest overlap, the Supreme Court generally refers to both claims as “false imprisonment.” Wallace v. Kato, 549 U.S. 384, 389, 127 S.Ct. 1091 (2007). A claim for false imprisonment is a claim of detention without adequate legal process, such as arrest and detention without a warrant or without a prompt probable cause hearing. The period of false imprisonment ends once the plaintiff is detained pursuant to a legal process. See generally, id., 127 S. Ct. 1091, 1095-96, 548 U.S. 384, 388-90. Here, that date was either February 28, 2022 (when Plaintiff was

arrested and arraigned in Municipal Court) or March 10, 2022 (the date that Plaintiff was indicted on drug charges in related Clermont County Common Pleas Case No. 2022 CR 235).2 Because the instant federal case was not initiated until Plaintiff’s in forma pauperis application and tendered complaint were filed on March 18, 2024, Defendants argue that Plaintiff’s complaint was filed after the applicable two-year statute of limitations that applies to § 1983 claims filed in Ohio. See, generally, Browning v. Pendleton, 869 F.2d 989, 992 (6th Cir. 1989); Lovelace v. O’Hara, 985 F.2d 847, 852 (6th Cir. 1993). In response, Plaintiff invokes the “prison mailbox rule,” a rule that “was created to prevent pro se prisoners from being penalized by any delays in filing caused by the prison mail system.” Cretacci v. Call, 988 F.3d 860, 867 (6th Cir. 2021). Under that rule, a

pleading by a prisoner is deemed to be “filed” when the prisoner transmits the document to prison officials for filing. See Richard v. Ray, 290 F.3d. 810, 813 (6th Cir. 2002) (per

2Defendants’ motion points out that Plaintiff was arraigned on the indictment in Case No. 2022 CR 235, and was given bond on March 11, 2022. that “reference to prison mail logs will generally be a straightforward inquiry, making … the date the pro se prisoner delivers the notice to prison authorities for mailing … a bright- line rule, not an uncertain one.”). In the case presented, Plaintiff asserts that he presented his civil complaint to prison officials for mailing on February 28, 2024, which arguably would make his claim for “prolonged detention” timely filed within two years of the date that his claim accrued.3 In support of that assertion, he points to a “cash statement” from his prison account that reflects two withdrawals for postage on February 29, 2024. (Doc. 16, PageID 146). Defendants urge this Court to reject Plaintiff’s assertion, pointing out that Plaintiff’s

original complaint was not signed “under penalty of perjury.” See Towns v. United States, 190 F.3d 468, 469 (6th Cir. 1999) (using date petition was signed “under penalty of perjury” as the operative date for the mailbox rule). Because Plaintiff did not submit a verified complaint “under penalty of perjury,” Defendants argue that he may not rely on the prison mailbox rule. But neither Towns nor any other controlling case law mandate that proof of delivery of mail to prison officials “under penalty of perjury” is required for the rule to apply. In the case presented, the pages of Plaintiff’s in forma pauperis application and the pages of his complaint form appear to have been intermingled. (See Doc. 1, PageID 9-12 (pages of complaint form)). The last page of the complaint form, on which the litigant

is asked to state his claims for “Relief” and sign and date the complaint form, appears in the midst of Plaintiff’s in forma pauperis application. (See Doc. 1, PageID 9).

3Although Plaintiff’s allegations are somewhat ambiguous, the undersigned infers that Plaintiff may be alleging he was wrongfully detained without probable cause until March 10, 2022 - the date that coincides with his indictment in No. 2022 CR 235. Plaintiff’s signature on both the in forma pauperis application and the complaint form is February 26, 2024. (See id., PageID 3, 9). But February 26 is not the operative date in this case, because Plaintiff included United States Marshal forms (USM 285) with his complaint that were not signed and dated until February 28, 2024. (See Doc. 1-4). The withdrawal from Plaintiff’s prison account for postage did not occur until the following day, February 29, 2024.

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Braunskill v. Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/braunskill-v-smith-ohsd-2025.