Brown v. Milwaukee County Jail

CourtDistrict Court, E.D. Wisconsin
DecidedFebruary 26, 2021
Docket2:20-cv-01367
StatusUnknown

This text of Brown v. Milwaukee County Jail (Brown v. Milwaukee County Jail) 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. Milwaukee County Jail, (E.D. Wis. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

MICHAEL BROWN,

Plaintiff,

v. Case No. 20-cv-1367

MILWAUKEE COUNTY JAIL and SHERIFF DAVID CLARKE,

Defendants.

SCREENING ORDER

Plaintiff Michael Brown, who was formerly an inmate 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 of 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 18, 2020 the court ordered Brown to pay an initial partial filing fee of $25.61. (Docket # 5.) Brown paid that fee on October 26, 2020. 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 Most of Brown’s allegations are substantively identical to the allegations that underly his other lawsuit, 19-cv-1285. In that case, Brown is proceeding against Sheriff David Clarke (also named in this case) for keeping him incarcerated in 2014 despite the alleged lack of a legal basis to do so. But he also includes a brief set of allegations that he was “illegally detained” at the Milwaukee County Jail between June and August 2018 and ultimately released when the district attorney “failed to provide documentation about [his] arrest and/or any criminal charges.” (Docket # 1 at 4.)

2.3 Analysis Brown cannot bring two lawsuits based on the same set of facts. His claims related to being detained at the Milwaukee County Jail in 2014 are already being litigated. Had Brown only included these allegations, I would have dismissed this lawsuit and issued him a strike. But his inclusion of the 2018 allegations means this complaint contains allegations not brought in his other lawsuit. Brown actually started his other lawsuit with allegations about 2018 but then shifted his attention to 2014 when I gave him the opportunity to amend his original complaint in that case, which did not state a claim. The allegations about his 2018 detention in this complaint also do not state a claim. It appears that Brown is attempting to state a claim under the Fourth Amendment for his 3 allegedly illegal detention. 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, as with his first complaint in his other lawsuit, this 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, as I have explained to Brown before, the Milwaukee County Jail is not a proper defendant. Section 1983 allows a plaintiff to sue a “person” who, acting under color of law, violates his constitutional rights, and the jail is not a person and is not 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 Monell v. Dep’t of Social Serv’s of City of New York, 436 U.S. 658 (1978). Federal Rule of Civil Procedure 17(b) says that a defendant in a federal lawsuit must have the legal capacity to be sued, and state law determines whether an entity has that capacity. Webb v. Franklin County Jail, Case No.

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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. Milwaukee County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-milwaukee-county-jail-wied-2021.