Cruikshank v. Ralph

CourtDistrict Court, D. Alaska
DecidedJuly 7, 2025
Docket4:25-cv-00010
StatusUnknown

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

Bluebook
Cruikshank v. Ralph, (D. Alaska 2025).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA WESLEY SCOTT CRUIKSHANK,

Plaintiff, Case No. 4:25-cv-00010-SLG v. ANNA E. RALPH, Defendant. SCREENING ORDER

On February 25, 2025, self-represented prisoner Wesley Scott Cruikshank (“Plaintiff”) filed a civil complaint and an application to waive prepayment of the filing fee.1 Plaintiff’s Complaint alleges that on or about February 22, 2023, Assistant District Attorney (“ADA”) Anna E. Ralph initiated a malicious prosecution against him by filing criminal charges in state court Case No. 4FA-23-00358CR.2

Plaintiff claims that several days before the trial, all charges in that case were dismissed against him by a different ADA.3 For relief, Plaintiff seeks $2 million in damages.4

1 Dockets 1-4. 2 Docket 1 at 1-2. 3 Docket 1 at 2. 4 Docket 1 at 2-3. Pursuant to Rule 201 of the Federal Rules of Evidence, the Court takes judicial notice of the Courtview records of the Alaska Court System and of the criminal case involving Plaintiff filed in federal court..5

The Court has now screened Plaintiff’s Complaint in accordance with 28 U.S.C. §§ 1915(e) and 1915A. For the reasons discussed in this order, Plaintiff's Complaint fails to adequately state a claim for which relief may be granted. Therefore, the Complaint is DISMISSED. However, Plaintiff is accorded 60 days to file an amended complaint that attempts to correct the deficiencies

identified in this order. If Plaintiff fails to respond to this order, of if the amended complaint is dismissed as frivolous, malicious, or for failure to state a claim and this case is closed, it will count as a “strike” under 28 U.S.C. §1915(g), which may limit Plaintiff’s ability to bring future cases under Section 1983 in federal court.

Alternatively, Plaintiff may file a notice of voluntarily dismissal in which he elects to close this case.

5 Judicial notice is the “court’s acceptance, for purposes of convenience and without requiring a party’s proof, of a well-known and indisputable fact; the court’s power to accept such a fact.” Black’s Law Dictionary (12th ed. 2024); See also United States ex rel. Robinson Rancheria Citizens Council v. Borneo, Inc., 971 F.2d 244, 248 (9th Cir. 1992) (“[W]e may take notice of proceedings in other courts, both within and without the federal judicial system, if those proceedings have a direct relation to matters at issue”) (internal citations and quotation marks omitted.). Case No. 4:25-cv-00010-SLG, Cruikshank v. Ralph SCREENING STANDARD Under the Prison Litigation Reform Act, a federal district court must screen complaints brought by prisoners seeking relief against a governmental entity or

officer or employee of a governmental entity.6 In this screening, a district court shall dismiss the case at any time if the court determines that the action: (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.7

In conducting its screening review, a district court must accept as true the allegations of the complaint, construe the pleading in the light most favorable to the plaintiff, and resolve all doubts in the plaintiff's favor.8 However, a court is not required to accept as true conclusory allegations, unreasonable inferences, or unwarranted deductions of fact.9 Although the scope of review generally is limited to the contents of the complaint, a court may also consider documents attached to the complaint, documents incorporated by reference in the complaint, or matters

6 28 U.S.C. §§ 1915, 1915A. 7 28 U.S.C. § 1915(e)(2)(B). 8Bernhardt v. L.A. County, 339 F.3d 920, 925 (9th Cir. 2003) (holding that a court must construe pleadings filed by self-represented litigants liberally and afford the complainant the benefit of any doubt). 9 Doe I v. Wal–Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation omitted). Case No. 4:25-cv-00010-SLG, Cruikshank v. Ralph of judicial notice.10 Such documents that contradict the allegations of a complaint may fatally undermine the complaint's allegations.11 Before a court may dismiss any portion of a complaint, a court must provide

a plaintiff with a statement of the deficiencies in the complaint and an opportunity to file an amended complaint, unless to do so would be futile.12 Futility exists when “the allegation of other facts consistent with the challenged pleading could not possibly cure the deficiency.”13 DISCUSSION

I. Requirements to State a Claim Rule 8 of the Federal Rules of Civil Procedure instructs that a complaint must contain a “short and plain statement of the claim showing that the [complainant] is entitled to relief[.]”14 While a complaint need not, and should not, contain every factual detail, “unadorned, the defendant-unlawfully-harmed-me accusation[s]” are insufficient to state a claim.15 To determine whether a complaint

states a valid claim for relief, a district court considers whether the complaint

10 United States v. Ritchie, 342 F.3d 903, 908 (9th Cir. 2003). 11 Sprewell v. Golden State Warriors, 266 F.3d 979, 988 (9th Cir. 2001), amended by 275 F.3d 1187 (2001) (noting that a plaintiff can “plead himself out of a claim by including . . . details contrary to his claims”). 12 Gordon v. City of Oakland, 627 F.3d 1092, 1094 (9th Cir. 2010) (citing Albrecht v. Lund, 845 F.2d 193, 195 (9th Cir. 1988)). 13 Schreiber Distributing Co. v. Serv-Well Furniture Co., 806 F.2d 1393, 1401 (9th Cir. 1986). 14 Fed. R. Civ. P. 8(a)(2). 15 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Case No. 4:25-cv-00010-SLG, Cruikshank v. Ralph contains enough facts that, if accepted as true, “state[s] a claim to relief that is plausible on its face.”16 A claim is plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant

is liable for the misconduct alleged.”17 Further, a federal court cannot act as an attorney for a self-represented litigant, such as by supplying the essential elements of a claim,18 and it is not a court’s responsibility to review filings or exhibits to identify possible claims. A complaint must allege that the plaintiff suffered a specific injury as a result of the

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