Conant v. Noble Correctional Inst.

CourtDistrict Court, S.D. Ohio
DecidedMay 17, 2023
Docket2:23-cv-01148
StatusUnknown

This text of Conant v. Noble Correctional Inst. (Conant v. Noble Correctional Inst.) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Conant v. Noble Correctional Inst., (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ROBERT JAMES CONANT, : Case No. 2:23-cv-1148 : Plaintiff, : District Judge Edmund A. Sargus, Jr. : Magistrate Judge Caroline H. Gentry vs. :

:

NOBLE CORRECTIONAL : ORDER AND REPORT INSTITUTION, et al., : AND RECOMMENDATION : Defendants. :

______________________________________________________________________ Plaintiff, a prisoner at the Chillicothe Correctional Institution, filed this pro se civil rights complaint pursuant to 42 U.S.C. § 1983 against the Noble Correctional Institution, Officer David Freeman, and Officer Shayna Bishop. (Doc. 1). By separate Order plaintiff has been granted leave to proceed in forma pauperis. This matter is before the Court for a sua sponte review of the complaint to determine whether the 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 Prison Litigation Reform Act of 1995 § 804, 28 U.S.C. § 1915(e)(2)(B); § 805, 28 U.S.C. § 1915A(b). Screening of Plaintiff’s Complaint A. Legal Standard Congress enacted 28 U.S.C. § 1915, the federal in forma pauperis statute, seeking to “lower judicial access barriers to the indigent.” Denton v. Hernandez, 504 U.S. 25, 31 (1992). In doing so, however, “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.’” Id. at 31 (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To address this concern, Congress included subsection (e)(1) as part of the statute, which provides in pertinent part: (2) Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that—

* * *

(B) the action or appeal—

(i) is frivolous or malicious;

(ii) fails to state a claim on which relief may be granted; or

(iii) seeks monetary relief against a defendant who is immune from such relief.

28 U.S.C. § 1915(e)(2)(B); Denton, 504 U.S. at 31. See also § 1915A(b). Thus, § 1915(e) requires sua sponte dismissal of an action upon the Court’s determination that the action is frivolous or malicious, or upon determination that the action fails to state a claim upon which relief may be granted. To state a claim upon which relief may be granted, a plaintiff must satisfy the basic federal pleading requirements set forth in Federal Rule of Civil Procedure 8(a). See also Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (applying Federal Rule of Civil Procedure 12(b)(6) standards to review under 28 U.S.C. §§ 1915A and 1915(e)(2)(B)(ii)). Under Rule 8(a)(2), a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Thus, Rule 8(a) “imposes legal and factual demands on the authors of complaints.” 16630 Southfield Ltd., P’Ship v. Flagstar Bank, F.S.B., 727 F.3d 502, 503 (6th Cir. 2013). Although this pleading standard does not require “‘detailed factual allegations,’ . . . [a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause

1 Formerly 28 U.S.C. § 1915(d). of action’” is insufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). A complaint will not “suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557). Instead, to survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a complaint

must contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). Facial plausibility is established “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. “The plausibility of an inference depends on a host of considerations, including common sense and the strength of competing explanations for the defendant’s conduct.” Flagstar Bank, 727 F.3d at 504 (citations omitted). Further, the Court holds pro se complaints “‘to less stringent standards than formal pleadings drafted by lawyers.’” Garrett v. Belmont Cnty. Sheriff’s Dep’t., No. 08-3978, 2010 WL 1252923, at *2 (6th Cir. April 1, 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). This lenient treatment, however, has limits; “‘courts should not have to guess at the nature of the claim asserted.’” Frengler v. Gen. Motors,

482 F. App’x 975, 976–77 (6th Cir. 2012) (quoting Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989)). B. Allegations in the Complaint Plaintiff alleges that on March 31, 2021, defendants Freeman and Bishop subjected him to excessive force. Plaintiff claims that on that date he was walking to the restroom when Freeman confronted and threatened him before slamming plaintiff’s head and face into a wall. According to plaintiff, he was slammed to the ground and knocked unconscious. Plaintiff alleges that while he was unconscious, defendant Bishop sprayed him in the face with mace. (Doc. 1 at PageID 5). As relief, plaintiff seeks monetary damages. (Id. at PageID 6). C. Analysis

At this stage in the proceedings, without the benefit of briefing by the parties to this action, the undersigned concludes that plaintiff’s excessive force claims against defendants Freeman and Bishop are deserving of further development and may proceed at this juncture. However, the complaint should be dismissed against the remaining defendant, the Noble Correctional Institution. See 28 U.S.C. §§ 1915(e)(2)(B) & 1915A(b). Title 42 U.S.C. § 1983

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Neil Frengler v. General Motors
482 F. App'x 975 (Sixth Circuit, 2012)
Hix v. Tennessee Department of Corrections
196 F. App'x 350 (Sixth Circuit, 2006)
Rodgers v. Michigan Department of Corrections
29 F. App'x 259 (Sixth Circuit, 2002)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)

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Conant v. Noble Correctional Inst., Counsel Stack Legal Research, https://law.counselstack.com/opinion/conant-v-noble-correctional-inst-ohsd-2023.