Curtis Lanson Mitchell v. Nancy A. Miller, ET AL.

CourtDistrict Court, E.D. Louisiana
DecidedNovember 10, 2025
Docket2:25-cv-02275
StatusUnknown

This text of Curtis Lanson Mitchell v. Nancy A. Miller, ET AL. (Curtis Lanson Mitchell v. Nancy A. Miller, ET AL.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Curtis Lanson Mitchell v. Nancy A. Miller, ET AL., (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

CURTIS LANSON MITCHELL * CIVIL ACTION

VERSUS * NO. 25-2275

NANCY A. MILLER, ET AL. * SECTION “D” (2)

SHOW CAUSE ORDER AND REASONS Plaintiff Curtis Lanson Mitchell filed a Complaint and Ex Parte Motion for Leave to Proceed in forma pauperis. ECF Nos. 1, 2. This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b) and Local Rule 72.1(B)(1). Plaintiff’s complaint asserts a variety of claims against police officer Linden Calvin, District Attorney Paul Connick and 24th Judicial District Court Judge Nancy Miller relating to an August 5, 2023, arrest and related detention. ECF No. 1 ¶ III. Citing to various federal criminal statutes and 42 U.S.C. § 1983, Plaintiff alleges that officer Calvin kidnapped him after which DA Connick and Judge Miller acted in concert with officer Calvin by setting bail (characterized by Plaintiff as ransom). Id. ¶¶ II(B), III(C). Plaintiff alleges that he was beaten and after being taken to the hospital, brought to jail. Id. ¶ IV. As relief, Plaintiff seeks damages of $500,000 and dismissal of all charges. Id. ¶ V. I. In Forma Pauperis Standard for Authorization to Proceed Without Payment A court may authorize the commencement of a civil action without the prepayment of fees or costs “by a person who submits an affidavit that includes a statement of all assets such [person] possesses that the person is unable to pay such fees or give security therefor.”1 Section 1915(a) “is intended to provide access to federal courts for plaintiffs who lack the financial resources to

1 28 U.S.C. § 1915(a)(1). pay statutory filing fees.”2 Courts assess plaintiff’s financial ability after considering whether payment of the filing fee would cause an undue financial hardship.3 This analysis entails a review of plaintiff’s income sources (including social security or unemployment payments4) and the demands on his financial resources, including whether expenses are discretionary or mandatory.5

While one need not be absolutely destitute to qualify for in forma pauperis status, such benefit is only allowed when a movant cannot give such costs and remain able to provide for himself and/or dependents.6 Whether to permit or deny an applicant to proceed in forma pauperis is within the sound discretion of the Court.7 Plaintiff’s application fails to identify any employer and indicates that he receives no wages, thus representing that he is unemployed. ECF No. 2 ¶ 2. Plaintiff represents that he has no income, no cash, checking or savings funds, no assets or liabilities, and no dependents. Id. ¶¶ 3-8. Based on the information provided by Plaintiff in his application, the Court finds that he cannot pay the filing fee without experiencing undue financial hardship. Accordingly, Plaintiff will be permitted to proceed in forma pauperis in the instant proceeding under the provisions of

28 U.S.C. § 1915(a), and his Complaint will be filed without pre-payment of fees or costs. This in forma pauperis status is granted subject to a later determination that the action should be dismissed if the allegation of poverty is untrue or the action is found to be frivolous or malicious

2 Prows v. Kastner, 842 F.2d 138, 140 (5th Cir. 1988). 3 Id. 4 Courts consider social security payments in making the in-forma-pauperis determination. See, e.g., Lewis v. Ctr. Mkt., 378 F. App’x 780, 784-85 (10th Cir. 2010) (affirming denial when appellant’s only income sources were social security and unemployment benefits); Salter v. Johnson, No. 12-738, 2013 WL 550654, *1 (S.D. Miss. Jan. 18, 2013) (noting income includes social security payments), R.&R. adopted, 2013 WL 55065 (S.D. Miss. Feb. 12, 2013). 5 Prows, 842 F.2d at 140. 6 Gibbs v. Jackson, 92 F.4th 566, 569 (5th Cir. 2024); Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948). 7 Prows, 842 F.2d at 140; 28 U.S.C. § 1915(a). under § 1915(e)(2). The Court may in its discretion impose costs of court against Plaintiff at the conclusion of this lawsuit, as in other cases.8 Summons will not be issued at this time, however, pending completion of this Court’s statutorily-mandated frivolous review.

II. Statutorily Mandated Review The Court is required by 28 U.S.C. § 1915(e) to review complaints filed by plaintiff in forma pauperis because there exists no absolute right to proceed in forma pauperis in federal civil matters.9 Rather, it is a privilege extended to those unable to pay filing fees when it is apparent that the claims do not lack merit on their face.10 And while pro se complaints are held to “less stringent standards” than attorney-drafted filings,11 pro se status does not constitute an impenetrable shield as even pro se litigants have no license to harass others, clog the judicial machinery with meritless litigation and abuse an already overloaded court system.12 Under § 1915(e)(2)(B), the Court must summarily dismiss in forma pauperis complaints if the court determines that the action: (1) is frivolous or malicious; (2) fails to state a claim on which

relief may be granted; or (3) seeks monetary relief against a defendant who is immune from such relief.13 A claim is frivolous when it lacks an arguable basis in law or in fact.14 A claim lacks an

8 See Moore v. McDonald, 30 F.3d 616, 621 (5th Cir. 1994). 9 This statutory review mandate applies equally to prisoner and non-prisoner in forma pauperis cases. James v. Richardson, 344 F. App’x 982, 983 (5th Cir. 2009) (“Section 1915(e)(2)(B) requires dismissal of frivolous IFP actions even if those actions are brought by non-prisoners plaintiffs.” (citing Newsome v. EEOC, 301 F.3d 227, 231 (5th Cir. 2002))); Newsome, 301 F.3d at 231 (applying § 1915(e)(2)(B) to a non-prisoner whose complaint was frivolous). 10 See Startii v. United States, 415 F.2d 1115, 1116 (5th Cir. 1969); see also Adepegba v. Hammons, 103 F.3d 383, 387 (5th Cir. 1996) (noting that the revocation of the privilege of proceeding in forma pauperis is not new), abrogated in part on other grounds by Coleman v. Tollefson, 575 U.S. 532, 536–37 (2015). 11 Haines v. Kerner, 404 U.S. 519, 520 (1972). 12 Farguson v. MBank Hou., N.A., 808 F.2d 358, 359 (5th Cir. 1986). 13 Amrhein v. United States, 740 F. App’x 65, 66 (5th Cir. 2018); Tam Vo v. St. Charles Par., No. 10-4624, 2011 WL 743466, at *1-2 (E.D. La. Feb. 3, 2011), R & R adopted sub nom., Vo v. St. Charles Par., NO. 10-4624, 2011 WL 740909 (E.D. La. Feb. 22, 2011). 14 Neitzke v. Williams, 490 U.S. 319, 325 (1989). arguable basis in law if it is “based on an indisputably meritless legal theory, such as if the complaint alleges the violation of a legal interest which clearly does not exist.”15 A complaint fails to state a claim on which relief may be granted when the factual allegations do not rise above a speculative level, with the assumption that all factual allegations in the complaint are true, even if doubtful.16

III. Analysis Initially, Plaintiff cites a variety of criminal statutes (18 U.S.C.

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