Brown v. Key

• Court: District Court, E.D. Arkansas
• Decided: October 3, 2025
• Docket: 3:25-cv-00208
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

EDWARD LEE BROWN PLAINTIFF

V. Case No. 3:25-CV-00208-JM

NATHANIAL KEY DEFENDANT

ORDER

Plaintiff Edward Lee Brown’s motion to proceed in forma pauperis (Doc. 1) is granted. He reports limited income. See Martin-Trigona v. Stewart, 691 F.2d 856, 857 (8th Cir. 1982) (per curiam) (complaint can be filed if plaintiff qualifies by economic status under 28 U.S.C. § 1915(a)). The law requires that I screen the Complaint. 28 U.S.C. § 1915(e)(2). “A pro se plaintiff must set forth enough factual allegations to ‘nudge [ ] their claims across the line from conceivable to plausible,’ or ‘their complaint must be dismissed’ for failing to state a claim upon which relief can be granted.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 569-70 (2007); see also Aschroft v. Iqbal, 556 U.S. 662, 678 (2009) (“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.”). Regardless of whether a plaintiff is represented or is appearing pro se, the plaintiff’s complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent, 780 F.2d 1334, 1337 (8th Cir. 1985). Brown’s Complaint is difficult to follow. (Doc. 2). Brown does not use a standard complaint form, has loosely narrated events, and has written his thoughts on various documents. Basically, there appears to have been some sort of an interaction between him and his neighbor Nathanial Key over Brown’s dogs barking. Police were called and an incident report was issued. Brown alleges a violation of his “liberty rights,” mentions his race, and names various police officers. It is not clear, however, who Brown intends to sue (Key or the responding officers), the cause of action (e.g., harassment, civil rights violation), or what relief Brown is requesting. Brown will be given 30 days from this Order to file an amended complaint curing the deficiencies identified in this order. If he chooses not to amend his complaint, or if his amended complaint does not cure the problems with his current complaint, then the Court will dismiss it without prejudice. Brown is warned that his amended complaint will take the place of his current complaint. That means that he must include any and all factual allegations in his amended complaint that he wants the Court to consider. The Court directs the Clerk to mail Brown a blank §1983 complaint and a blank civil complaint. Brown need only return one completed complaint depending on the cause of action he intended to bring. IT IS SO ORDERED this 3? day of October, 2025.

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