CARTER v. PHELPS

CourtDistrict Court, M.D. Georgia
DecidedFebruary 13, 2025
Docket3:24-cv-00098
StatusUnknown

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

Bluebook
CARTER v. PHELPS, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION

ANTAWYN CARTER, : : Plaintiff, : : v. : Case No. 3:24-CV-98-CDL-CHW : JUDGE CHRIS PHELPS, : : Defendant. : ________________________________ :

ORDER AND RECOMMENDATION

In accordance with the Court’s previous orders and instructions, pro se Plaintiff Antawyn Carter, an inmate in the Jenkins Correction Center in Millen, Georgia, has paid the required initial partial filing fee in this case. Plaintiff’s motion to compel jail staff to submit this payment (ECF No. 6) is accordingly DENIED as moot. Plaintiff’s claims are now ripe for review pursuant to 28 U.S.C. §§ 1915A and 1915(e). For the reasons set forth below, it is RECOMMENDED that Plaintiff’s Complaint be DISMISSED without prejudice. PRELIMINARY SCREENING OF PLAINTIFF’S COMPLAINT I. Standard of Review

The Prison Litigation Reform Act (“PLRA”) obligates the district courts to conduct a preliminary screening of every complaint filed by a prisoner who seeks redress from a government entity, official, or employee. See 28 U.S.C. § 1915A(a). Screening is also required under 28 U.S.C. § 1915(e) when the plaintiff is proceeding IFP. Both statutes apply in this case, and the standard of review is the same. Pro se pleadings are held “to a less stringent standard than a pleading drafted by an attorney; a pro se pleading is liberally

construed.” Danglar v. Dep’t of Corr., 50 F.4th 54, 56 n.4 (11th Cir. 2022) (quoting Jones v. Fla. Parole Comm’n, 787 F.3d 1105, 1107 (11th Cir. 2015)). Still, the Court must dismiss a prisoner complaint if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. §1915A(b); see also 28 U.S.C. § 1915(e). A claim is frivolous if it “lacks an arguable basis either in law or in fact.” Miller v.

Donald, 541 F.3d 1091, 1100 (11th Cir. 2008) (internal quotation marks omitted). The Court may dismiss claims that are based on “indisputably meritless legal” theories and “claims whose factual contentions are clearly baseless.” Id. (internal quotation marks omitted). A complaint fails to state a claim if it does not include “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 Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The factual allegations in a complaint “must be enough to raise a right to relief above the speculative level” and cannot “merely create[] a suspicion [of] a legally cognizable right of action.” Twombly, 550 U.S. at 555 (first alteration in original). In other words, the complaint must allege enough facts “to raise a reasonable expectation that discovery will

reveal evidence” supporting a claim. Id. at 556. “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. To state a claim for relief under § 1983, a plaintiff must allege that (1) an act or omission deprived him of a right, privilege, or immunity secured by the Constitution or a

statute of the United States; and (2) the act or omission was committed by a person acting under color of state law. Hale v. Tallapoosa Cnty., 50 F.3d 1579, 1582 (11th Cir. 1995). If a litigant cannot satisfy these requirements or fails to provide factual allegations in support of his claim or claims, the complaint is subject to dismissal. See Chappell v. Rich, 340 F.3d 1279, 1282-84 (11th Cir. 2003).

II. Factual Allegations and Plaintiff’s Claims Plaintiff’s claims arise from his present imprisonment. ECF No. 1 at 4. He is essentially seeking his release from prison and a return of his personal property on grounds that his constitutional and statutory rights were violated in connection with his conviction. See id. at 6. Plaintiff names as Defendants in this action two state officials who handled his state criminal case, Judge Chris Phelps and District Attorney Parks White. Id. at 1, 3.

Plaintiff’s Complaint bears the “hallmarks of the ‘sovereign citizen’ theory that has been consistently rejected by the federal courts as an utterly frivolous attempt to avoid the statutes, rules, and regulations that apply to all litigants, regardless of how they portray themselves.” Mells v. Loncon, No. CV 418-296, 2019 WL 1339618, at *2 (S.D. Ga. Feb. 27, 2019) (emphasis in original). So-called “sovereign citizens” generally “believe they

are not subject to the jurisdiction of the courts.” United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 2013). A sovereign citizen’s pleadings are often peppered with official- sounding—but ultimately meaningless—legalese, and they typically suggest that the individual is beyond the jurisdiction of the courts or otherwise immune from criminal prosecution or legal action. See, e.g., United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (noting that “sovereign citizens” raise theories “of individual sovereignty, immunity

from prosecution, and their ilk”). Plaintiff’s filing also bears some indications of reliance on the related “Redemptionist” theory, which “propounds that a person has a split personality: a real person and a fictional person called the ‘strawman.’” Monroe v. Beard, 536 F.3d 198, 203 n.4 (3d Cir. 2009).

Redemptionists claim that government has power only over the strawman and not over the live person, who remains free. Individuals can free themselves by filing UCC filing statements, thereby acquiring an interest in their strawman. Thereafter, the real person can demand that government officials pay enormous sums of money to use the strawman’s name or, in the case of prisoners, to keep him in custody.

Id. Both the “sovereign citizen” and “Redemptionist” theories are frivolous legal theories that have been consistently rejected by federal courts. See, e.g., Trevino v. Florida, 687 F. App’x 861, 862 (11th Cir. 2017) (per curiam) (finding plaintiff’s sovereign citizen arguments frivolous and “clearly baseless”); Linge v. State of Georgia Inc., 569 F. App'x 895, 896 (11th Cir. 2014) (finding the sovereign citizen argument to be to “wholly insubstantial and frivolous”); United States v. Hilgeford, 7 F.3d 1340, 1342 (7th Cir.1993) (rejecting sovereign citizen argument as “shop worn” and frivolous); Muhammad v. Smith, No.

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CARTER v. PHELPS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carter-v-phelps-gamd-2025.