Brown v. Clark

CourtDistrict Court, E.D. Wisconsin
DecidedAugust 27, 2020
Docket2:19-cv-01285
StatusUnknown

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

Bluebook
Brown v. Clark, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

MICHAEL BROWN,

Plaintiff,

v. Case No. 19-CV-1285

MILWAUKEE COUNTY JAIL and SHERIFF DAVID CLARKE,

Defendants.

SCREENING ORDER

Plaintiff Michael Brown, an inmate confined at the Drug Abuse Correctional Center, filed a pro se complaint under 42 U.S.C. § 1983 alleging that the defendants violated his rights under federal law while he was in custody at the Milwaukee County Jail. This matter is now before me on Brown’s motion for leave to proceed without prepaying the filing fee and for screening his complaint. 1. Motion for Leave to Proceed without Prepaying the Filing Fee The Prison Litigation Reform Act (“PLRA”) applies to this case because Brown was a prisoner when he filed his complaint. See 28 U.S.C. § 1915(h). The PLRA allows the court to give a prisoner plaintiff the ability to proceed with his case without prepaying the civil case filing fee. 28 U.S.C. § 1915(a)(2). When funds exist, the prisoner must pay an initial partial filing fee. 28 U.S.C. § 1915(b)(1). He must then pay the balance of the $350 filing fee over time, through deductions from his prisoner account. Id. On September 5, 2019 the court ordered Brown to pay an initial partial filing fee of $4.99. (Docket # 5.) Brown paid that fee on September 23, 2019. I will grant Brown’s motion for leave to proceed without prepaying the filing fee. He must pay the remainder of the filing fee over time in the manner explained at the end of this order.

2. Screening the Complaint 2.1 Federal Screening Standard Under the PLRA, I must screen complaints brought by prisoners seeking relief from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). I must dismiss a complaint if the prisoner raises claims that are legally “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). In determining whether the complaint states a claim, I apply the same standard that applies to dismissals under Federal Rule of Civil Procedure 12(b)(6). See Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017) (citing Booker-El v. Superintendent, Ind. State Prison, 668 F.3d 896,

899 (7th Cir. 2012)). To state a claim, a complaint must include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The complaint must contain enough facts, accepted as true, to “state a claim for 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)). “A claim has facial plausibility when the plaintiff pleads factual content that allows a court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). To state a claim for relief under 42 U.S.C. § 1983, a plaintiff must allege that someone deprived him of a right secured by the Constitution or the laws of the United States, and that 2 whoever deprived him of this right was acting under color of state law. D.S. v. E. Porter Cty. Sch. Corp., 799 F.3d 793, 798 (7th Cir. 2015) (citing Buchanan–Moore v. Cty. of Milwaukee, 570 F.3d 824, 827 (7th Cir. 2009)). I construe pro se complaints liberally and holds them to a less stringent standard than pleadings drafted by lawyers. Cesal, 851 F.3d at 720 (citing Perez v.

Fenoglio, 792 F.3d 768, 776 (7th Cir. 2015)). 2.2 Brown’s Allegations Brown alleges that he was illegally detained at the Milwaukee County Jail between June 2018 and August 2018. This was the second time he was detained based on a dismissed arrest warrant from Kansas City. When the district attorney failed to provide the documentation about his arrest and/or criminal charges, a judge ordered him released from custody. He seeks damages for the “illegal detainment of [his] person in 2014 and 2018.” 2.3 Analysis Brown’s complaint is short on allegations. But construed liberally, Brown attempts to

assert a claim related to his alleged unlawful imprisonment in the Milwaukee County Jail, which is cognizable under the Fourth Amendment. Knox v. Smith, 342 F.3d 651, 657 (7th Cir.2003) (noting that wrongful detention by a state official is a Fourth Amendment violation actionable under 42 U.S.C. § 1983). However, his complaint does not state a claim because he has named one improper defendant (the jail) and one defendant against whom he makes no factual allegations (former Sheriff Clarke). First, the Milwaukee County Jail is not a proper defendant because § 1983 allows a plaintiff to sue a “person” who, acting under color of law, violates his constitutional rights. The jail is not a person. It is not an individual subject to suit under §1983. It is true that under

some circumstances, a municipality—which is not a person—may be sued under § 1983. See 3 Monell v. Dep’t of Social Serv’s of City of New York, 436 U.S. 658 (1978). But Federal Rule of Civil Procedure 17(b) says that a defendant in a federal lawsuit must have the legal capacity to be sued. State law determines whether an entity has that capacity. Webb v. Franklin County Jail, Case No. 16-cv-1284, 2017 WL 914736, at *2 (S.D. Ill. Mar. 8, 2017). In Wisconsin, the jail

is an arm of the sheriff’s department. Under Wisconsin law, the sheriff’s department is an arm of the County. See Abraham v. Piechowski, 13 F. Supp.2d 870, 877–79 (E.D. Wis. 1998). This means that neither the jail nor the sheriff’s department are “legal entit[ies] separable from the county government which [they] serve[] . . . .” Whiting v. Marathon C’nty Sheriff’s Department, 382 F.3d 700, 704 (7th Cir. 2004)). And while defendant former Sheriff Clarke could be a proper defendant, Brown does not include any allegations against him in his complaint.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Booker-El v. Superintendent, Indiana State Prison
668 F.3d 896 (Seventh Circuit, 2012)
Paul Knox v. Deborah Smith
342 F.3d 651 (Seventh Circuit, 2003)
Buchanan-Moore v. County of Milwaukee
570 F.3d 824 (Seventh Circuit, 2009)
Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Abraham v. Piechowski
13 F. Supp. 2d 870 (E.D. Wisconsin, 1998)
Miguel Perez v. James Fenoglio
792 F.3d 768 (Seventh Circuit, 2015)
D. S. v. East Porter County School Corp
799 F.3d 793 (Seventh Circuit, 2015)
Cesal v. Moats
851 F.3d 714 (Seventh Circuit, 2017)

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Brown v. Clark, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-clark-wied-2020.