Counts v. American Psychological Assn.

CourtDistrict Court, S.D. Illinois
DecidedMay 5, 2025
Docket3:25-cv-00558
StatusUnknown

This text of Counts v. American Psychological Assn. (Counts v. American Psychological Assn.) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Counts v. American Psychological Assn., (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

JOSEPH COUNTS, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-00558-JPG ) AMERICAN PSYCHOLOGICAL ) ASSOCIATION, ) ) Defendant. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Joseph Counts brings this action against the American Psychological Association pursuant to the Federal Tort Claims Act, 28 U.S.C. §§ 1346, 2671-2680. This matter is before the Court for review of the Complaint (Doc. 1) pursuant to 28 U.S.C. § 1915(e)(2)(B) and for a decision on a Motion for Leave to Proceed in forma pauperis (“IFP”) (Doc. 2). For the reasons set forth below, the Complaint is DISMISSED, and the IFP motion is DENIED. An indigent plaintiff may bring a case in federal court without paying the required costs or fees by submitting an affidavit asserting the inability “to pay such fees or give security therefor” and stating, “the nature of the action, defense or appeal, and the affiant’s belief that the person is entitled to redress.” 28 U.S.C. § 1915(a)(1). Plaintiff’s affidavit does not demonstrate that he is indigent for purposes of this action. He discloses gross wages of $1,350 per month, a total bank account balance of $3,680, and a net account balance of $675. (Doc. 2, pp. 2-3). He has sufficient funds to pay the $405 filing fee for this action. However, the Court’s inquiry does not end there. Section 1915(e)(2) also requires consideration of a complaint filed by a plaintiff seeking leave to proceed IFP. 28 U.S.C. § 1915(e)(2). Pursuant to § 1915(e)(2)(B), the Court may dismiss a case or deny an otherwise qualified plaintiff leave to proceed IFP, if the action is clearly frivolous or malicious, fails to state a claim, or is a claim for money damages against an immune defendant. Hoskins v. Poelstra, 320 F.3d 761, 763 (7th Cir. 2003). Plaintiff’s Complaint fails to state a claim on which relief may be granted, and the IFP motion will therefore be denied. The Complaint Plaintiff alleges that he underwent a mental competency evaluation while in the custody of

the Federal Bureau of Prisons (FBOP). (Doc. 1, p. 6). From January through April 2022, he was sent to Metropolitan Correctional Center in Chicago, Illinois (MCC-Chicago) for the evaluation. Plaintiff was diagnosed with “delusional disorder ‘grandiose’ type” in a report issued May 2022. This report formed the basis of Honorable Stephen P. McGlynn’s adjudication of incompetence in Plaintiff’s pending criminal case in the United States District Court for the Southern District of Illinois.1 Plaintiff faults Dr. Kristin Conlon (APA evaluator) and Dr. Krissin (FBOP psychologist) for their role in the “defamatory” diagnosis. Id. He seeks money damages from the American Psychological Association. Id. at 7. Discussion

The Complaint does not survive review under 28 U.S.C. § 1915(e)(2)(B). Plaintiff brings a claim against the American Psychological Association pursuant to the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 1346, 2671-80. The FTCA provides jurisdiction for suits against the United States for torts committed by federal officials while acting in the scope of their employment. See id. The only proper defendant in an FTCA action is the United States. See Jackson v. Kotter, 541 F.3d 688 (7th Cir. 2008) (citing Kaba v. Stepp, 458 F.3d 678, 681 (7th Cir. 2006)). Plaintiff did not name the United States as a defendant. He also did not bring this suit for the alleged misconduct of federal officials who were acting within the scope of their employment.

1 Plaintiff is presumably referring to United States v. Counts, No. 3:21-cr-30068-SPM (S.D. Ill.), where Judge McGlynn found that he was not competent to stand trial. See Dkt. Entries 152-53. He sues the American Psychological Association for the findings made during his evaluation. The FTCA provides no avenue to relief against the American Psychological Association. The Complaint thus fails to state a claim upon which relief may be granted and will be dismissed under § 1915(e)(2)(B). The Court has considered whether to allow an amendment and declines to do so here.

Plaintiff cannot pursue a defamation claim under the FTCA. See 28 U.S.C. § 2680(h). The FTCA does not apply to any claim arising out of libel or slander. Id.; Nance v. United States, App. No. 21-1181, 2024 WL 4502107, at *2 (7th Cir. Oct. 16, 2024) (finding that plaintiff could not succeed on a conspiracy claim under applicable state law, and the underlying torts of abuse of process, defamation, misrepresentation, and deceit were excluded under FTCA); Figuero v. U.S. Postal Service, 165 F.3d 32 (7th Cir. 1998) (unpublished) (citing Jimenez-Nieves v. United States, 682 F.2d 1 (1st Cir. 1982) (the exception covers all claims of defamation)). Even if Plaintiff was granted leave to amend the complaint to pursue a claim for money damages against those individuals who completed his mental competency evaluation, the claims

could not proceed. The United States Supreme Court has recognized an implied damages remedy against individual federal officers in only three contexts, including a case involving a Fourth Amendment unreasonable search and seizure claim in Bivens v. Six Unknown Named Agents, 403 U.S. 388, 392 (1971), a Fifth Amendment gender discrimination claim in Davis v. Passman, 442 U.S. 228 (1979), and an Eighth Amendment medical deliberate indifference claim in Carlson v. Green, 446 U.S. 14 (1980). Beyond this, the Supreme Court has rejected every proposed extension of this implied damages remedy in the past 45 years and made it clear that further expansion of the remedy is strongly disfavored. See Egbert v. Boule, 596 U.S. 482 (2022); Brooks v. Richardson, 131 F.4th 613, 614 (7th Cir. 2025). A Bivens-type claim against the individual evaluators does not fit within any of these contexts. Even if it did, Plaintiff could not pursue his claim for money damages against the individual evaluators. An action brought pursuant to Bivens will still be defeated if a defendant is immune from suit. Egbert, 596 U.S. at 493, n.2 (citing Hui v. Castaneda, 559 U.S. 799, 807 (2010)). Psychological evaluators are “protected by the same immunity extended to judges and other judicial officers.” Bartlett v.

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Related

Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Hui v. Castaneda
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Kelsey D. Bartlett v. Dr. Robert E. Weimer
268 F.2d 860 (Seventh Circuit, 1959)
Anna Duzynski v. Victoria Nosal
324 F.2d 924 (Seventh Circuit, 1963)
Rudolph Lucien v. Diane Jockisch
133 F.3d 464 (Seventh Circuit, 1998)
James Hoskins v. John Poelstra
320 F.3d 761 (Seventh Circuit, 2003)
Ammons v. Gerlinger
547 F.3d 724 (Seventh Circuit, 2008)
Jackson v. Kotter
541 F.3d 688 (Seventh Circuit, 2008)
Egbert v. Boule
596 U.S. 482 (Supreme Court, 2022)
Tate v. SCR Medical Transportation
809 F.3d 343 (Seventh Circuit, 2015)
Terrell Esco v. City of Chicago
107 F.4th 673 (Seventh Circuit, 2024)
Kevin Brooks v. Josh Richardson
131 F.4th 613 (Seventh Circuit, 2025)

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