Bullock v. The City of Richmond

CourtDistrict Court, E.D. Virginia
DecidedSeptember 18, 2025
Docket3:25-cv-00126
StatusUnknown

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

Bluebook
Bullock v. The City of Richmond, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division CHARLIE BELL BULLOCK, Plaintiff, v. Civil Action No. 3:25CV126 DETECTIVE DAVID CUFFLEY, et al., Defendants. MEMORANDUM OPINION Charlie Bell Bullock, a Virginia inmate proceeding pro se and in forma pauperis, filed this 42 U.S.C. § 1983 action.! By Memorandum Order entered on July 18, 2025, the Court directed the plaintiff to file a Particularized Complaint. (ECF No. 11.) Bullock then filed a Particularized Complaint. (ECF No, 12.) The matter is before the Court for evaluation of Bullock’s compliance with the Court’s July 18, 2025, Memorandum Order and pursuant to 28 U.S.C. §§ 1915(e)(2) and 1915A. The action will be DISMISSED for failure to state a claim and because it is legally frivolous and malicious. I. PRELIMINARY REVIEW Pursuant to the Prison Litigation Reform Act (“PLRA”), this Court must dismiss any action filed by a prisoner if the Court determines the action (1) “is frivolous” or (2) “fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2); see 28 U.S.C. § 1915A. The first

' The statute provides, in pertinent part: Every person who, under color of any statute ... of any State . . . subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action atlaw.... 42 U.S.C. § 1983.

standard includes claims based upon “an indisputably meritless legal theory,” or claims where the “factual contentions are clearly baseless.” Clay v. Yates, 809 F. Supp. 417, 427 (E.D. Va. 1992) (quoting Neitzke v. Williams, 490 U.S. 319, 327 (1989)). The second standard is the familiar standard for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). “A motion to dismiss under Rule 12(b)(6) tests the sufficiency of a complaint; importantly, it does not resolve contests surrounding the facts, the merits of a claim, or the applicability of defenses.” Republican Party of N.C. v. Martin, 980 F.2d 943, 952 (4th Cir. 1992) (citing 5A Charles A. Wright & Arthur R. Miller, Federal Practice and Procedure § 1356 (1990)). In considering a motion to dismiss for failure to state a claim, a plaintiff's well-pleaded allegations are taken as true and the complaint is viewed in the light most favorable to the plaintiff. Mylan Labs., Inc. v. Matkari, 7 F.3d 1130, 1134 (4th Cir. 1993); see also Martin, 980 F.2d at 952. This principle applies only to factual allegations, however, and “a court considering a motion to dismiss can choose to begin by identifying pleadings that, because they are no more than conclusions, are not entitled to the assumption of truth.” Ashcroft v. Igbal, 556 U.S. 662, 679 (2009). The Federal Rules of Civil Procedure “require[ ] only ‘a short and plain statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (second alteration in original) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). Plaintiffs cannot satisfy this standard with complaints containing only “labels and conclusions” or a “formulaic recitation of the elements of a cause of action.” /d. (citations omitted). Instead, a plaintiff must allege facts sufficient “to raise a right to relief above the speculative level,” id. (citation omitted), and state a claim that is “plausible on its face,” id. at 570, rather than merely “conceivable.” Jd. “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.” Iqbal, 556 U.S. at 678 (citing Bell Atl. Corp., 550 U.S. at 556). For a claim or complaint to survive dismissal for failure to state a claim, therefore, the plaintiff must “allege facts sufficient to state all the elements of [his or] her claim.” Bass v. E. DuPont de Nemours & Co., 324 F.3d 761, 765 (4th Cir. 2003) (first citing Dickson v. Microsoft Corp., 309 F.3d 193, 213 (4th Cir. 2002), then Jodice v. United States, 289 F.3d 270, 281 (4th Cir. 2002)). Lastly, while the Court liberally construes pro se complaints, Gordon v. Leeke, 574 F.2d 1147, 1151 (4th Cir. 1978), it does not act as the inmate’s advocate, sua sponte developing statutory and constitutional claims the inmate failed to clearly raise on the face of his complaint. See Brock v. Carroll, 107 F.3d 241, 243 (4th Cir. 1997) (Luttig, J., concurring); Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985). II. PROCEDURAL HISTORY AND ALLEGATIONS In January 2017, Bullock was convicted in the Circuit Court for the City of Richmond, Virginia, of being a felon in possession of a firearm, use of a firearm second offense, and malicious wounding. See Bullock v. Cuffey, No. 3:17CV95—HEH, 2019 WL 3130398, at *2 (E.D. Va. June 26, 2018) (citations omitted). In 2017, Bullock filed a § 1983 complaint in this Court arguing that a variety of individuals involved in securing his criminal conviction violated his rights. See id. The Court dismissed the action for failure to state a claim upon which relief may be granted, and as frivolous and malicious. Undeterred by the prior unfavorable opinion by this Court, Bullock has filed yet another action against many of the same defendants. (ECF No. 1.) By Memorandum Order entered on July 18, 2025, the Court directed Bullock to file a particularized complaint, and explained as follows: In order to state a viable claim under 42 U.S.C. § 1983," a plaintiff must allege that a person acting under color of state law deprived him or her of a constitutional right or of a right conferred by a law of the United States. See Dowe v. Total Action Against Poverty in Roanoke Valley, 145 F.3d 653, 658 (4th Cir. 1998) (citing 42 U.S.C. § 1983). Courts must liberally construe pro se civil rights complaints in

order to address constitutional deprivations. Gordon v. Leeke, 574 F.2d 1147, 1151 (4th Cir. 1978).

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Bullock v. The City of Richmond, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bullock-v-the-city-of-richmond-vaed-2025.