Cunningham v. Miller

CourtDistrict Court, S.D. Ohio
DecidedOctober 29, 2024
Docket1:24-cv-00603
StatusUnknown

This text of Cunningham v. Miller (Cunningham v. Miller) 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.

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Cunningham v. Miller, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

CAROL YVONNE CUNNINGHAM, Case No. 1:24-cv-603 Plaintiff, Barrett, J. vs. Litkovitz, M.J.

SUE MILLER, REPORT AND Defendant. RECOMMENDATION

Plaintiff Carol Yvonne Cunningham, a resident of Cincinnati, Ohio, has filed a pro se civil complaint against Sue Miller, a care coordinator with the Council on Aging Elderly Services Program in Blue Ash, Ohio. (Doc. 1-1). By separate Order, plaintiff has been granted leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. This matter is now 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 28 U.S.C. § 1915(e)(2)(B). Screening of Complaint A. Legal Standard In enacting the original in forma pauperis statute, 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.” Denton v. Hernandez, 504 U.S. 25, 31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To prevent such abusive litigation, Congress has authorized federal courts to dismiss an in forma pauperis complaint if they are satisfied that the action is frivolous or malicious. Id.; see also 28 U.S.C. § 1915(e)(2)(B)(i). A complaint may be dismissed as frivolous when the plaintiff cannot make any claim with a rational or arguable basis in fact or law. Neitzke, 490 U.S. at 328-29; see also Lawler v. Marshall, 898 F.2d 1196, 1198 (6th Cir. 1990). An action has no arguable legal basis when the defendant is immune from suit or when plaintiff claims a violation of a legal interest which clearly does not exist. Neitzke, 490 U.S. at 327. An action

has no arguable factual basis when the allegations are delusional or rise to the level of the irrational or “wholly incredible.” Denton, 504 U.S. at 32; Lawler, 898 F.2d at 1199. The Court need not accept as true factual allegations that are “fantastic or delusional” in reviewing a complaint for frivolousness. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (quoting Neitzke, 490 U.S. at 328). Congress also has authorized the sua sponte dismissal of complaints that fail to state a claim upon which relief may be granted. 28 U.S.C. § 1915 (e)(2)(B)(ii). A complaint filed by a pro se plaintiff must be “liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). By the same token, however,

the complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Hill, 630 F.3d at 470-71 (“dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim” under §§ 1915A(b)(1) and 1915(e)(2)(B)(ii)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). The Court must accept all well-

2 pleaded factual allegations as true, but need not “accept as true a legal conclusion couched as a factual allegation.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). Although a complaint need not contain “detailed factual allegations,” it must provide “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S.

at 678 (citing Twombly, 550 U.S. at 555). A pleading that offers “labels and conclusions” or “a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. The complaint must “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Erickson, 551 U.S. at 93 (citations omitted). B. Plaintiff’s Complaint Ms. Cunningham has submitted a complaint and several attachments. As best the Court can discern from these documents, plaintiff was receiving services from the Council on Aging, Hamilton County Elderly Services Program. She was presented with a “Contracted Agreement for Continuing Services” in January 2024, which alleged that plaintiff had a history of difficult

and argumentative behaviors that inhibited her providers from addressing her needs. (Doc. 1-1 at PAGEID 8). The contract required plaintiff to treat Council on Aging staff with respect and consideration and to engage in an open dialogue. Plaintiff refused to sign the contract and alleges the information about her behavior is untrue. She states she does not argue about her needed health care. She alleges the agency should be investigated for not taking care of their clients and seeks a monetary judgment of “ten thousand dollars for lack of basic health needs.” (Doc. 1-1 at PAGEID 6).

3 C. Resolution Ms. Cunningham’s allegations are insufficient to state a claim with an arguable basis in law over which this federal Court has subject matter jurisdiction. First, Ms. Cunningham’s civil cover sheet indicates she is bring a claim under the False

Claims Act, 31 U.S.C. § 3729, et seq. The False Claims Act “prohibits any person from making false or fraudulent claims for payment to the United States.” McGhee v. Light, 384 F. Supp. 3d 894, 897 (S.D. Ohio 2019) (quoting Graham Cnty. Soil & Water Conservation Dist. v. U.S. ex rel. Wilson, 545 U.S. 409, 411, (2005) (citing 31 U.S.C. § 3729), report and recommendation adopted, No. 3:19-cv-143 (S.D. Ohio June 6, 2019) (Doc. 5). While “private individuals may bring qui tam actions in the Government’s name for § 3729 violations,” a pro se plaintiff is prohibited from bringing a qui tam action on behalf of the Government and the federal courts lack subject matter jurisdiction to hear such claims. Id.; Brantley v. Title First Titling Agency, No. 1:12-cv-608, 2012 WL 6725592, at *3 (S.D. Ohio Sept.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Metropolitan Life Insurance v. Taylor
481 U.S. 58 (Supreme Court, 1987)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
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)
Callihan v. Schneider
178 F.3d 800 (Sixth Circuit, 1999)
McGhee v. Light
384 F. Supp. 3d 894 (S.D. Ohio, 2019)

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