Crawford v. Carlson

CourtDistrict Court, D. Utah
DecidedMarch 4, 2025
Docket2:23-cv-00549
StatusUnknown

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

Bluebook
Crawford v. Carlson, (D. Utah 2025).

Opinion

THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

CRAIG CRAWFORD,

MEMORANDUM DECISION AND Plaintiff, ORDER TO CURE DEFICIENT AMENDED COMPLAINT v. Case No. 2:23-cv-00549-JNP BRIAN REDD et al., District Judge Jill N. Parrish

Defendants.

Plaintiff Craig Crawford, acting pro se, brought this civil-rights action, see 42 U.S.C.S. § 1983 (2025).1 Having now screened his Amended Complaint, (ECF No. 10), under its statutory review function, 28 U.S.C.S. § 1915A (2025),2 the Court orders Plaintiff to file a second amended complaint curing deficiencies before further pursuing claims.

1 The federal statute creating a "civil action for deprivation of rights" reads, in pertinent part: Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory . . ., subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. 42 U.S.C.S. § 1983 (2025). 2 The screening statute reads: (a) Screening.—The court shall review . . . a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. (b) Grounds for dismissal.—On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint— (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. A. AMENDED COMPLAINT'S DEFICIENCIES 1. It appears that Plaintiff attempted to add a new request for relief to the Amended Complaint by filing a motion for a permanent injunction. ECF No. 12. Any request for such relief must be added to any second amended complaint filed by Plaintiff.

2. The Amended Complaint must be amended with the understanding that, under the Ex parte Young exception to Eleventh Amendment sovereign immunity, a plaintiff may sue individual state officers acting in their official capacities if the complaint alleges an ongoing violation of federal law and the plaintiff seeks prospective relief. See Ex parte Young, 209 U.S. 123, 159-60 (1908); Verizon Md. Inc. v. Pub. Serv. Comm'n of Md., 535 U.S. 635, 645 (2002); Hendrickson v. AFSCME Council 18, 992 F.3d 950, 965 (10th Cir. 2021).

3. The Amended Complaint has claims possibly based on current confinement; however, the complaint was apparently not submitted using legal help Plaintiff is constitutionally entitled to by his institution--i.e., the prison contract attorneys. See Lewis v. Casey, 518 U.S. 343, 356 (1996) (requiring prisoners be given "'adequate law libraries or adequate assistance from persons trained in the law' . . . to ensure that inmates . . . have a reasonably adequate opportunity to file nonfrivolous legal claims challenging their convictions or conditions of confinement") (quoting Bounds v. Smith, 430 U.S. 817, 828 (1977) (emphasis added)).

B. GUIDANCE FOR PLAINTIFF Rule 8 of the Federal Rules of Civil Procedure requires a complaint to contain "(1) a short and plain statement of the grounds for the court's jurisdiction . . .; (2) a short and plain statement of the claim showing that the pleader is entitled to relief; and (3) a demand for the relief sought." Rule 8's requirements mean to guarantee "that defendants enjoy fair notice of what the claims against them are and the grounds upon which they rest." TV Commc'ns Network, Inc. v ESPN, Inc., 767 F. Supp. 1062, 1069 (D. Colo. 1991). Pro se litigants are not excused from meeting these minimal pleading demands. "This is so because a pro se plaintiff requires no special legal training to recount the facts surrounding his alleged injury, and he must provide such facts if the court is to determine whether he makes out a

28 U.S.C.S. § 1915A (2025). claim on which relief can be granted." Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). Moreover, it is improper for the Court "to assume the role of advocate for a pro se litigant." Id. Thus, the Court cannot "supply additional facts, [or] construct a legal theory for plaintiff that assumes facts that have not been pleaded." Dunn v. White, 880 F.2d 1188, 1197 (10th Cir. 1989). Plaintiff should consider these points before filing an amended complaint: • The revised complaint must stand entirely on its own and shall not refer to, or incorporate by reference, any part of the original complaint(s). See Murray v. Archambo, 132 F.3d 609, 612 (10th Cir. 1998) (stating amended complaint supersedes original). Also, an amended complaint may not be added to after filing without moving for amendment. Fed. R. Civ. P. 15.

• Each defendant must be named in the complaint's caption, listed in the section of the complaint setting forth names of each defendant, and affirmatively linked to applicable claims within the "cause of action" section of the complaint. • The complaint must clearly state what each individual defendant--typically, a named government employee--did to violate Plaintiff's civil rights. See Bennett v. Passic, 545 F.2d 1260, 1262-63 (10th Cir. 1976) (stating personal participation of each named defendant is essential allegation in civil-rights action). "To state a claim, a complaint must 'make clear exactly who is alleged to have done what to whom.'" Stone v. Albert, 338 F. App'x 757, 759 (10th Cir. 2009) (unpublished) (emphasis in original) (quoting Robbins v. Oklahoma, 519 F.3d 1242, 1250

(10th Cir. 2008)). Plaintiff should also include, as much as possible, specific dates or at least estimates of when alleged constitutional violations occurred. • Each cause of action, together with the facts and citations that directly support it, should be stated separately. Plaintiff should be as brief as possible while still using enough words to fully explain the "who," "what," "where," "when," and "why" of each claim. Robbins, 519 F.3d at 1248 ("The [Bell Atlantic Corp. v.] Twombly Court was particularly critical of complaints that 'mentioned no specific, time, place, or person involved in the alleged [claim].' [550 U.S. 544, 565] n.10 (2007). Given such a complaint, 'a defendant seeking to respond to plaintiff's conclusory allegations . . . would have little idea where to begin.' Id.").

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Murray v. Archambo
132 F.3d 609 (Tenth Circuit, 1998)
Steffey v. Orman
461 F.3d 1218 (Tenth Circuit, 2006)
Stone v. Albert
338 F. App'x 757 (Tenth Circuit, 2009)
Gallagher v. Shelton
587 F.3d 1063 (Tenth Circuit, 2009)
Howard Smith Bennett v. Albert Passic, Sheriff, Etc.
545 F.2d 1260 (Tenth Circuit, 1976)
Emmett Ray McCarthy v. Dr. F. Weinberg, M.D.
753 F.2d 836 (Tenth Circuit, 1985)
Hall v. Bellmon
935 F.2d 1106 (Tenth Circuit, 1991)
Gross v. General Motors LLC
441 F. App'x 562 (Tenth Circuit, 2011)
Gregory Lee Rucks v. Gary Boergermann
57 F.3d 978 (Tenth Circuit, 1995)
TV Communications Network, Inc. v. ESPN, Inc.
767 F. Supp. 1062 (D. Colorado, 1991)
Rachel v. Troutt
820 F.3d 390 (Tenth Circuit, 2016)

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Crawford v. Carlson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crawford-v-carlson-utd-2025.