Davis v. Hamilton County Court of Common Pleas

CourtDistrict Court, S.D. Ohio
DecidedApril 19, 2022
Docket1:22-cv-00187
StatusUnknown

This text of Davis v. Hamilton County Court of Common Pleas (Davis v. Hamilton County Court of Common Pleas) 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.

Bluebook
Davis v. Hamilton County Court of Common Pleas, (S.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

JEREMY DAVIS, et al., Case No. 1:22-cv-187 Plaintiffs, Cole, J. Litkovitz, M.J. vs.

HAMILTON COUNTY COURT REPORT AND OF COMMON PLEAS, et al., RECOMMENDATION Defendants.

Plaintiffs Jeremy Davis and Stephanie Kinley, residents of Cincinnati, Ohio, have filed a pro se civil complaint against the Hamilton County Court of Common Pleas, Dave Yost, Joseph Gruber, Tom Heekin, Pavan Parikh, and Patrick Dinkelacker. (Doc. 1-1). By separate Order, plaintiff Kinley 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 Prison Litigation Reform Act of 1995 § 804, 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

2 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- 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. Plaintiffs’ Complaint Plaintiffs’ complaint contains general allegations concerning the rate of incarceration in Ohio’s prisons; the high rate of death due to COVID 19 among incarcerated individuals; and the

failure of local, state, and federal officials to reduce the prison population to prevent illness and death. (Doc. 1-1 at PAGEID 6). Plaintiffs further allege that “Ohio is using its human beings as instruments of chattle (sic) to pay the U.S. Inc. debt,” and the justice system in Hamilton County, Ohio is being controlled by a “mainly all white staff. . . .” (Id.). As relief, plaintiffs “would like for the court to seize 4661 Hamilton Avenue in Cincinnati, Ohio 45223 (for starters) and transfer it into our names permanently including soil and mineral rights, or into an LLC of our choice.” (Id. at PAGEID 7). In addition, plaintiffs state they would be willing to accept from the State of Ohio any vacant property and rehab such property. Finally, among other

3 things, plaintiffs seek the restructuring of the justice system to focus on human beings. (Id.). C. Resolution Plaintiffs’ allegations are insufficient to state a claim with an arguable basis in law over which this federal Court has subject matter jurisdiction.

As an initial matter, to the extent plaintiffs allege that state, local, and federal governments have violated the rights of incarcerated individuals, plaintiffs lack standing to raise the claims of others. See Allen v. Wright, 468 U.S. 737, 751 (1984) (“[s]tanding . . . embraces several judicially self-imposed limits on the exercise of federal jurisdiction, such as the general prohibition on a litigant’s raising another person’s legal rights. . . .”). By law, an individual may appear in federal court only pro se or through legal counsel. 28 U.S.C. § 1654. Although plaintiffs purport to represent thousands of incarcerated individuals, they are not lawyers and may not represent any other individuals in this matter. See Bonacci v. Kindt, 868 F.2d 1442, 1443 (5th Cir. 1989); Lewis v. Lena-Smith Mfg.

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Thomas v. Arn
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Bluebook (online)
Davis v. Hamilton County Court of Common Pleas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-v-hamilton-county-court-of-common-pleas-ohsd-2022.