CHRISTOPHER F. JONES v. DANNY L. DURHAM and E. TIMOTHY O’BRIEN

CourtDistrict Court, S.D. Georgia
DecidedDecember 4, 2025
Docket1:25-cv-00124
StatusUnknown

This text of CHRISTOPHER F. JONES v. DANNY L. DURHAM and E. TIMOTHY O’BRIEN (CHRISTOPHER F. JONES v. DANNY L. DURHAM and E. TIMOTHY O’BRIEN) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CHRISTOPHER F. JONES v. DANNY L. DURHAM and E. TIMOTHY O’BRIEN, (S.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF GEORGIA

AUGUSTA DIVISION

CHRISTOPHER F. JONES, ) ) Plaintiff, ) ) v. ) CV 125-124 ) DANNY L. DURHAM and E. TIMOTHY ) O’BRIEN, ) ) Defendants. )

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

Plaintiff, currently incarcerated at Federal Correctional Institution McDowell in Welch, West Virginia, filed this case pursuant to 42 U.S.C. § 1983, concerning events alleged to have taken place in Augusta, Georgia. He is proceeding pro se and in forma pauperis (“IFP”). Because he is proceeding IFP, Plaintiff’s complaint must be screened to protect potential defendants. Phillips v. Mashburn, 746 F.2d 782, 785 (11th Cir. 1984) (per curiam); Al-Amin v. Donald, 165 F. App’x 733, 736 (11th Cir. 2006) (per curiam). I. SCREENING THE COMPLAINT A. BACKGROUND In his complaint, Plaintiff named Danny L. Durham and E. Timothy O’Brien, his retained defense attorneys, as Defendants. (Doc. no. 2, pp. 1, 2.) Taking all of Plaintiff’s allegations as true, as the Court must for purposes of the present screening, the facts are as follows. In April of 2022, Plaintiff retained Defendant Durham as his defense attorney in two state criminal cases. (Id. at 5.) “Mr. Durham did not defend the plaintiff of the state pending offenses during his federal trial . . . after plaintiff was federally sentence[d] he was sent to face pending state charges.” (Id.) After Defendant Durham sought legal assistance from an “appeal specialist” to assess if there was error in the federal trial proceeding, and the specialist “did not find anything wrong”, Defendant Durham “ceased and abandoned Plaintiff[‘s] case. .

. while Plaintiff[’s] case was pending and avoided his obligation to his client.” (Id.) Defendant O’Brien “was also involved in this situation… when Danny L. Durham neglected his obligation in July 2022 during an attorney-client visit at [Charles B. Webster Detention Center]” because Defendant O’Brien deprived him of his “attorney-client confidentiality rights” by calling a family member in the United States Attorney’s Office for information on Plaintiff’s indictment. (Id.) Plaintiff alleges both defendants failed to adequately represent him by neglecting to “address the Court with motions that would have made a difference in the outcome of the trial,” by failing to go over the Presentence Investigation Report with Plaintiff, by attempting to withdraw from representing Plaintiff, and by failing to follow up on

information which would have bolstered Plaintiff’s case and led to a different outcome for his federal trial. (Id. at 6-7.) Plaintiff states “he is not challenging his conviction or sentence here[.]” (Id. at 8.) He seeks money damages from each Defendant and injunctive relief in the form of disbarring both Defendants. (Id. at 9.) B. DISCUSSION 1. Legal Standard for Screening The complaint or any portion thereof may be dismissed if it is frivolous, malicious, or fails

to state a claim upon which relief may be granted, or if it seeks monetary relief from a defendant who is immune to such relief. See 28 U.S.C. § 1915A(b). A claim is frivolous if it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). Failure to state a claim under § 1915A(b) is “no different from a dismissal under Federal Rule of Civil Procedure 12(b)(6).” White v. Lemma, 947 F.3d 1373, 1377 (11th Cir. 2020) (per curiam) (citing Jones v. Bock, 549 U.S. 199, 215-16 (2007)), abrogated on other grounds by Wells v. Brown, 58

F.4th 1347 (11th Cir. 2023). To avoid dismissal for failure to state a claim upon which relief can be granted, the allegations in the complaint must “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “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.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). That is, “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550

U.S. at 555. While Rule 8(a) of the Federal Rules of Civil Procedure does not require detailed factual allegations, “it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A complaint is insufficient if it “offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action,’” or if it “tenders ‘naked assertions’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 555, 557). In short, the complaint must provide a “‘plain statement’ possess[ing] enough heft to ‘sho[w]

that the pleader is entitled to relief.’” Twombly, 550 U.S. at 557 (quoting Fed. R. Civ. P. 8(a)(2)). Finally, the Court affords a liberal construction to a pro se litigant’s pleadings, holding them to a more lenient standard than those drafted by an attorney. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam); Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). However, this liberal construction does not mean that the Court has a duty to re-write the complaint. Snow v. DirecTV, Inc., 450 F.3d 1314, 1320 (11th Cir. 2006). 2. Plaintiff Fails to State a Valid § 1983 Claim Against Defendants

Defendants Durham and O’Brien are not proper parties under § 1983 because they are not state actors. To establish a § 1983 claim, a plaintiff must show “the conduct complained of (1) was committed by a person acting under color of state law and (2) deprived the complainant of rights, privileges, or immunities secured by the Constitution or laws of the United States.” Harvey v. Harvey, 949 F.2d 1127, 1130 (11th Cir. 1992). “[A] defense attorney is not a state actor under section 1983.” Rolle v. Raysor, 267 F. App’x 925, 926 (11th Cir. 2008). A “defense attorney in private practice . . . is not deemed to be an actor under the ‘color of state law.’ Even a defense attorney employed [by] the Public Defender’s Office ‘does not act under color of state law when performing a lawyer’s traditional functions as counsel to a defendant in a criminal proceeding.’” Christopher v. Gourjian, No. 2:10-CV-498, 2010 WL 3294344 (M.D. Fla. Aug.

20, 2010) (quoting Polk Cty. v. Dodson, 454 U.S. 312, 325 (1981)).

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CHRISTOPHER F. JONES v. DANNY L. DURHAM and E. TIMOTHY O’BRIEN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-f-jones-v-danny-l-durham-and-e-timothy-obrien-gasd-2025.