Bryant v. Ratliff

CourtDistrict Court, E.D. Missouri
DecidedAugust 12, 2025
Docket2:25-cv-00033
StatusUnknown

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

Bluebook
Bryant v. Ratliff, (E.D. Mo. 2025).

Opinion

EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

JEFFREY PAUL BRYANT, ) ) Plaintiff, ) ) v. ) No. 2:25-CV-00033 JMB ) RUSTY RATLIFF, et al., ) ) Defendants. )

OPINION, MEMORANDUM AND ORDER

This matter is before the Court upon the motion of self-represented plaintiff Jeffrey Bryant, an inmate at Southeast Correctional Center (SECC), for leave to commence this action without payment of the required filing fee. [ECF No. 2]. For the reasons stated below, the Court finds that the plaintiff does not have sufficient funds to pay the entire filing fee and will assess an initial partial filing fee of $1.00. See 28 U.S.C. § 1915(b)(1). Furthermore, based upon a review of the complaint, the Court finds that the complaint should be dismissed pursuant to 28 U.S.C. § 1915(e)(2)(B). Initial Partial Filing Fee Pursuant to 28 U.S.C. § 1915(b)(1), a prisoner bringing a civil action in forma pauperis is required to pay the full amount of the filing fee. If the prisoner has insufficient funds in his or her prison account to pay the entire fee, the Court must assess and, when funds exist, collect an initial partial filing fee of 20 percent of the greater of (1) the average monthly deposits in the prisoner’s account, or (2) the average monthly balance in the prisoner’s account for the prior six-month period. After payment of the initial partial filing fee, the prisoner is required to make monthly payments of 20 percent of the preceding month’s income credited to the prisoner’s account. 28 U.S.C. § 1915(b)(2). The agency having custody of the prisoner will forward these monthly the filing fee is fully paid. Id.

Plaintiff has not submitted a certified prison account statement. As a result, the Court will require plaintiff to pay an initial partial filing fee of $1.00. See Henderson v. Norris, 129 F.3d 481, 484 (8th Cir. 1997) (when a prisoner is unable to provide the Court with a certified copy of his prison account statement, the Court should assess an amount “that is reasonable, based on whatever information the court has about the prisoner’s finances.”). If plaintiff is unable to pay the initial partial filing fee, he must submit a copy of his prison account statement in support of his claim. Legal Standard on Initial Review Under 28 U.S.C. § 1915(e)(2), the Court is required to dismiss a complaint filed in forma pauperis if it is frivolous, malicious, or fails to state a claim upon which relief can be granted. To

state a claim, a plaintiff must demonstrate a plausible claim for relief, which is more than a “mere possibility of misconduct.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (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.” Id. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw upon judicial experience and common sense. Id. at 679. The court must “accept as true the facts alleged, but not legal conclusions or threadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Barton v. Taber, 820 F.3d 958, 964 (8th Cir. 2016). See also Brown v. Green Tree Servicing LLC, 820 F.3d 371, 372-73 (8th Cir. 2016) (stating the court must accept factual allegations in the complaint as true but is not required to “accept as

true any legal conclusion couched as a factual allegation”). When reviewing a self-represented complaint under § 1915(e)(2), the Court must give it the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972). A “liberal construe the plaintiff’s complaint in a way that permits his or her claim to be considered within

the proper legal framework. Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015). However, even self-represented complaints are required to allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). See also Stone v. Harry, 364 F.3d 912, 914-15 (8th Cir. 2004) (stating that federal courts are not required to “assume facts that are not alleged, just because an additional factual allegation would have formed a stronger complaint”). In addition, affording a self-represented complaint the benefit of a liberal construction does not mean that procedural rules in ordinary civil litigation must be interpreted so as to excuse mistakes by those who proceed without counsel. See McNeil v. United States, 508 U.S. 106, 113 (1993).

The Complaint Plaintiff Jeffrey Bryant, an inmate at SECC, brings this prisoner civil rights claim under 42 U.S.C. § 1983 against five named defendants and five John Doe defendants for alleged civil rights violations that allegedly occurred during his incarceration at Moberly Correctional Center (MCC) in Moberly, Missouri. The five named defendants in this action are: Warden Rusty Ratliff, Correctional Officer Unknown Davee; Correctional Officer J. Morrison; Medical Provider Jermey Unknown; and Nurse Jane Huff. Plaintiff sues the five named defendants in their official capacities only. Plaintiff alleges that during his incarceration at MCC on or about April 5, 2024, a Code 16 (possible seizure) was called on the radio system. Plaintiff admits that due to his medical condition

at the time, he does not recall the events in question; however, he states that there is video evidence which the Court can obtain from MCC. restraints. He identifies one of the officers who responded as Officer Unknown Davee. He does

not, however, indicate what Officer Davee is accused of doing. He also fails to indicate who placed him in restraints and if this occurred immediately after he was found. Plaintiff has attached various grievance documents to his complaint, which the Court takes notice of pursuant to Federal Rule of Civil Procedure 10(c).1 In the Warden’s Response, dated June 13, 2024, the response notes that plaintiff claimed that at the time of the incident he had “slurred incoherent speech and glassy and vacant eyes. . .” It is unclear if plaintiff was having a medical emergency or if he had ingested a substance of some kind or what the Missouri Department of Corrections’ (MDOC) officials believed had occurred at the time of the incident. It appears, however, that the MDOC officials treated the event as an overdose.

After plaintiff was placed in restraints, an altercation occurred between plaintiff and several MDOC officials. The Institutional Resolution Responses, Grievance Appeal Responses and Warden Responses plaintiff has attached to his complaint make reference to an assault by plaintiff on Correctional Officer Morrison during an attempt by MDOC officials to escort him to medical. Plaintiff, however, alleges in his complaint that “shortly after submitting to restraints, [he] was peper [sic] sprayed” by Officer Morrison.

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Bryant v. Ratliff, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryant-v-ratliff-moed-2025.