Campbell v. Butler County Jail

District Court, S.D. Ohio·Decided September 9, 2025·No. 1:23-cv-00763·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

LE-LON CAMPBELL, : Case No. 1:23-cv-763 : Plaintiff, : District Judge Michael R. Barrett : Magistrate Judge Peter B. Silvain, Jr. vs. : : BUTLER COUNTY JAIL, et al., : : Defendants. : : ORDER AND REPORT AND RECOMMENDATION1

Plaintiff, a prisoner currently housed at the Manchester Federal Correctional Institution, in Manchester, Kentucky, has filed a pro se civil rights action, alleging that his constitutional rights were violated when he was housed as a federal pretrial detainee at the Butler County Jail (Jail). The operative pleading in this case is Plaintiff’s Amended Complaint (Doc. 17), which supersedes his initial Complaint (Doc. 1-1) for all purposes. See Scuba v. Wilkinson, No. 1:06-cv-160, 2006 WL 2794939, at *2 (S.D. Ohio Sept. 27, 2006) (citing Parry v. Mohawk Motors of Mich., Inc., 236 F.3d 299, 306 (6th Cir. 2000)). By separate Order, Plaintiff has been granted leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. (Doc. 16). Observing that it was unclear from Plaintiff’s initial filings whether he had sufficient funds to prepay the filing fee in this matter, the Court entered two Show Cause Orders concerning his in forma pauperis application. (Docs. 3; 11). When Plaintiff failed to respond to the Second Show Cause Order, the undersigned issued a Report and Recommendation to dismiss the case for want of prosecution. (Doc. 12). Thereafter, Plaintiff filed motions clarifying that he lacked sufficient

1 Attached is a NOTICE to the parties regarding objections to this Report and Recommendation. funds to prepay the full filing fee. (Docs. 13; 14). For good cause shown, the undersigned vacated the Report and Recommendation to dismiss the case for want of prosecution and permitted Plaintiff to proceed in forma pauperis in accordance with 28 U.S.C. § 1915(b). (Doc. 16). This matter is now before the Court for a sua sponte review of the Amended Complaint to determine whether the Amended Complaint or any portion of it should be dismissed because it is

frivolous, malicious, fails to state a claim upon which relief may be granted or seeks monetary relief from a Defendant who is immune from such relief. See 28 U.S.C. §§ 1915(e)(2)(B) & 1915A(b). Also before the Court is Plaintiff’s Motion for Clarity and Next Steps. (Doc. 18). Screening of Complaint A. Legal Standard In enacting the original in forma pauperis statute, Congress recognized that a “litigant whose filing fees and court costs are assumed by the public, unlike a paying litigant, lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits.” Denton v. Hernandez, 504 U.S. 25, 31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To

prevent such abusive litigation, Congress has authorized federal courts to dismiss an in forma pauperis complaint if they are satisfied that the action is frivolous or malicious. Id.; see also 28 U.S.C. §§ 1915(e)(2)(B)(i) and 1915A(b)(1). A complaint may be dismissed as frivolous when the plaintiff cannot make any claim with a rational or arguable basis in fact or law. Neitzke, 490 U.S. at 328-29; see also Lawler v. Marshall, 898 F.2d 1196, 1198 (6th Cir. 1990). An action has no arguable legal basis when the defendant is immune from suit or when plaintiff claims a violation of a legal interest which clearly does not exist. Neitzke, 490 U.S. at 327. An action has no arguable factual basis when the allegations are delusional or rise to the level of the irrational or “wholly incredible.” Denton, 504 U.S. at 32; Lawler, 898 F.2d at 1199. The Court need not accept as true factual allegations that are “fantastic or delusional” in reviewing a complaint for frivolousness. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (quoting Neitzke, 490 U.S. at 328). Congress also has authorized the sua sponte dismissal of complaints that fail to state a claim upon which relief may be granted. 28 U.S.C. §§ 1915 (e)(2)(B)(ii) and 1915A(b)(1). A complaint filed by a pro se plaintiff must be “liberally construed” and “held to less stringent

standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). By the same token, however, the complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to 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)); see also Hill, 630 F.3d at 470-71 (“dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim” under §§ 1915A(b)(1) and 1915(e)(2)(B)(ii)). “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 Twombly, 550 U.S. at 556). The Court must accept all well-pleaded factual allegations as true, but need not “accept as true a legal conclusion couched as a factual allegation.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). Although a complaint need not contain “detailed factual allegations,” it must provide “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). A pleading that offers “labels and conclusions” or “a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. The complaint must “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Erickson, 551 U.S. at 93 (citations omitted). B. The Amended Complaint The Amended Complaint arises out of Plaintiff’s allegations that pretrial detainees at the Jail are not allowed any outdoor recreation. (Doc. 17, PageID 77). Plaintiff names three

Defendants—the Jail, Sheriff Richard K. Jones, and the “U.S. Marshals,” by which the Court understands Plaintiff to mean the United States Marshals Service (USMS). Because the Defendants are both county and federal officials, the Court understands the Amended Complaint to arise under both 42 U.S.C. § 1983 and Bivens v. Six Unknown Named Agents of Fed.

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