Cronin v. Idaho Department of Health and Welfare (IDHW)

CourtDistrict Court, D. Idaho
DecidedJuly 1, 2025
Docket2:25-cv-00337
StatusUnknown

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

Bluebook
Cronin v. Idaho Department of Health and Welfare (IDHW), (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

LISA CRONIN, Case No. 2:25-cv-00337-AKB Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

IDAHO DEPARTMENT OF HEALTH AND WELFARE; MARIA MARTINDALE; MAGGIE MORRISON; SHAWNY LEE; TAYLOR WOODMAN; and ELIJAH WOODMAN,

Defendants.

Pending before the Court is Plaintiff Lisa Cronin’s Application for Leave to Proceed in Forma Pauperis (Dkt. 1) and her Complaint (Dkt. 2). Pursuant to 28 U.S.C. § 1915, this Court must review Plaintiff’s request to determine whether she is entitled to proceed in forma pauperis, which permits civil litigants to proceed without prepayment of the full filing fee or to pay the filing fee over time. Rice v. City of Boise City, No. 1:13-CV-00441-CWD, 2013 WL 6385657, at *1 (D. Idaho Dec. 6, 2013). The Court must also undertake an initial review of Plaintiff’s complaint to ensure it meets the minimum required standards. See 28 U.S.C. § 1915(e)(2). For the reasons below, the Court denies Plaintiff’s Application for Leave to Proceed In Forma Pauperis and dismisses her Complaint without prejudice.

INITIAL REVIEW ORDER BY SCREENING JUDGE - 1 I. APPLICATION TO PROCEED IN FORMA PAUPERIS Any party instituting a civil action in a federal district court is required to pay a filing fee. 28 U.S.C. § 1914. On application, however, a party may proceed in forma pauperis. 28 U.S.C. § 1915. The Court “may authorize the commencement, prosecution or defense of any suit, action

or proceeding, civil or criminal, or appeal therein, without prepayment of fees or security therefor[.]” 28 U.S.C. § 1915(a)(1). To qualify for in forma pauperis status, a plaintiff must submit an affidavit that includes a statement of all assets she possesses and that indicates she is unable to pay the fee required. Id. The affidavit is sufficient if it states the plaintiff, because of her poverty, cannot “pay or give security for the costs” and still be able to provide for herself and dependents the “necessities of life.” Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948). The affidavit must “state the facts as to affiant’s poverty with some particularity, definiteness and certainty.” United States v. McQuade, 647 F.2d 938, 940 (9th Cir. 1981) (internal quotation marks omitted). The Court has reviewed Plaintiff’s In Forma Pauperis Application, which reports that

Plaintiff receives a total of $1,776 in average monthly income (Dkt. 1 at 1-2). Plaintiff reports average monthly expenses of $693, which includes rent or home mortgage payment, utilities, food, clothing, laundry, transportation, and recreation (id. at 4). Therefore, in an average month, Plaintiff has roughly $1,083 in income after she pays her monthly expenses. These factors indicate Plaintiff can pay the Court’s filing fee while still supporting her basic living expenses. Because Plaintiff has not provided information to demonstrate her poverty, the Court denies Plaintiff’s application to proceed In Forma Pauperis.

INITIAL REVIEW ORDER BY SCREENING JUDGE - 2 II. SUFFICIENCY OF THE COMPLAINT The Court is required to screen complaints brought by litigants who seek in forma pauperis status. See 28 U.S.C. § 1915(e)(2). The Court must dismiss a complaint, or any portion thereof, if it: (1) is frivolous or malicious; (2) fails to state a claim upon which relief can be granted; or

(3) seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915(e)(2)(B)(i-iii). During this review, courts generally construe pro se pleadings liberally, giving pro se plaintiffs the benefit of any doubt. See Resnick v. Hayes, 213 F.3d 443, 447 (9th Cir. 2000); see also Crotts v. Cnty. of Los Angeles, 990 F.2d 1256, *1 (9th Cir. 1993) (unpublished table opinion) (“In civil rights actions, allegations of a pro se complaint, however inartfully pleaded, should be liberally construed.”) (citing Lopez v. Dep’t of Health Servs, 939 F.2d 881, 882-83 (9th Cir. 1991)) (per curiam). Even so, plaintiffs—whether represented or not—have the burden of articulating their claims clearly and alleging facts sufficient to support review of each claim. Pena v. Gardner, 976 F.2d 469, 471 (9th Cir. 1992). Additionally, if amending the complaint would remedy the

deficiencies, plaintiffs should be notified and provided an opportunity to amend. See Jackson v. Carey, 353 F.3d 750, 758 (9th Cir. 2003). Plaintiff’s action must be dismissed because this Court may not interfere with the ongoing state proceeding from which she seeks relief. Under the Younger Doctrine, federal courts are to give proper respect to state functions, including the state courts, and therefore, are not to interfere with (1) ongoing state proceedings that (2) implicate important state interests and (3) give adequate opportunity to raise constitutional issues. Potrero Hills Landfill, Inc. v. Cnty. of Solano, 657 F.3d 876, 882 (9th Cir. 2011) (quoting Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass'n, 457

INITIAL REVIEW ORDER BY SCREENING JUDGE - 3 U.S. 423, 432 (1982)). Additionally, the Ninth Circuit has explained that abstention is appropriate when (4) the federal court’s action would, in effect, enjoin the state proceedings. Id. The Younger Doctrine applies to civil proceedings “that implicate a State’s interest in enforcing the orders and judgments of its courts.” Mulholland v. Marion Cnty. Election Bd., 746 F.3d 811, 815 (7th Cir.

2014) (quoting Sprint Communs., Inc. v. Jacobs, 571 U.S. 69, 72-73 (2013)). Additionally, as a background principal, “[f]ederal courts customarily decline to intervene in the realm of domestic relations.” Lewton v. Divingnzzo, 772 F. Supp. 2d 1046, 1061 (D. Neb. 2011); see also Elk Grove Unified Sch. Dist. v. Newdow, 542 U.S. 1, 12 (2004) (“One of the principal areas in which [the Supreme Court] has customarily declined to intervene is in the realm of domestic relations.”), abrogated on other grounds by Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014).

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Cronin v. Idaho Department of Health and Welfare (IDHW), Counsel Stack Legal Research, https://law.counselstack.com/opinion/cronin-v-idaho-department-of-health-and-welfare-idhw-idd-2025.