Chatman v. Missouri Department of Corrections

CourtDistrict Court, E.D. Missouri
DecidedJuly 17, 2023
Docket1:23-cv-00055
StatusUnknown

This text of Chatman v. Missouri Department of Corrections (Chatman v. Missouri Department of Corrections) 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
Chatman v. Missouri Department of Corrections, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

BENJAMIN CHATMAN, ) ) Plaintiff, ) ) v. ) No. 1:23-cv-00055-NCC ) MISSOURI DEPARTMENT ) OF CORRECTIONS, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter comes before the Court on the motion of plaintiff Benjamin Chatman for leave to commence this civil action without prepayment of the required filing fee. (Docket No. 3). Having reviewed the motion and the financial information submitted in support, the Court finds that plaintiff lacks sufficient funds to pay the entire filing fee, and will assess an initial partial filing fee of $57.61. See 28 U.S.C. § 1915(b)(1). Additionally, for the reasons discussed below, the Court will dismiss plaintiff’s complaint without prejudice. 28 U.S.C. § 1915(b)(1) 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 payments to the Clerk of Court each time the amount in the prisoner’s account exceeds $10.00, until the filing fee is fully paid. Id. In support of his motion for leave to proceed in forma pauperis, plaintiff has submitted a copy of his inmate account statement. (Docket No. 4). The account statement shows an average

monthly deposit of $288.03. The Court will therefore assess an initial partial filing fee of $57.61, which is 20 percent of plaintiff’s average monthly deposit. 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 avoid dismissal, 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 that court must accept factual allegations in complaint as true, but is not required to “accept as true any legal conclusion couched as a factual allegation”). When reviewing a pro se complaint under 28 U.S.C. § 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 construction” means that if the essence of an allegation is discernible, the district court should 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 pro se 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 pro se 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 is a self-represented litigant who is currently incarcerated as a pretrial detainee at the St. Louis City Justice Center in St. Louis, Missouri. The events described in the complaint took place while he was an inmate at the Southeast Correctional Center (SECC) in Charleston. Plaintiff brings this civil action pursuant to 42 U.S.C. § 1983, naming the Missouri Department of

Corrections, Director Anne Precythe, Deputy Warden Bill Stange, and Vocational Enterprise Supervisor Jodie Rumnier as defendants. (Docket No. 1 at 1). Precythe and Stange are sued in their individual capacities only. (Docket No. 1 at 2-3). Plaintiff does not indicate the capacity in which Rumnier is sued. The complaint contains allegations that plaintiff was wrongfully held in prison after his underlying convictions and sentences had been vacated. In the “Statement of Claim,” plaintiff sets forth two separate claims. First, he alleges unlawful imprisonment, asserting that on September 30, 2022, he received notice that his “29.15 post-conviction relief motion was granted, and [his] convictions … vacated and remanded for a new trial.” (Docket No. 1 at 4). According to plaintiff, the State of Missouri was given forty days from the date his motion was granted to file a notice of appeal. He contends that the appeal deadline was November 8, 2022, but he remained in the SECC until December 6, 2022. During this time, plaintiff states he continuously inquired as to why he remained “at the prison without conviction.” Plaintiff asserts that the delay in leaving SECC violated his Eighth and Fourteenth Amendment

rights. Second, plaintiff asserts that he was made to continue his prison job in violation of the Thirteenth Amendment. In particular, he alleges that even after his convictions were vacated, he “was forced to continue with [his] work program under threats of punishment,” receiving pay of fifteen cents an hour. Plaintiff states that this amounts to “slave wages” and therefore violates the Thirteenth Amendment’s proscription of slavery, and the guarantee of “fair pay/wages for work performed.” By way of further explanation, plaintiff has attached a “Brief Narrative of Events [Surrounding] Claims.” (Docket No. 1 at 5).

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Bluebook (online)
Chatman v. Missouri Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chatman-v-missouri-department-of-corrections-moed-2023.