DUGGANS v. THE GA DHR SERVICES

CourtDistrict Court, M.D. Georgia
DecidedJuly 2, 2025
Docket3:25-cv-00100
StatusUnknown

This text of DUGGANS v. THE GA DHR SERVICES (DUGGANS v. THE GA DHR SERVICES) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DUGGANS v. THE GA DHR SERVICES, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION CORNELIUS DUGGANS, Plaintiff, CIVIL ACTION NO. v. 3:25-cv-100-TES GEORGIA DHR SERVICES, Defendant.

ORDER

Pro se Plaintiff Cornelius Duggans commenced this civil action on June 17, 2025, by filing a Complaint [Doc. 1] and moving for leave to proceed in forma pauperis (“IFP”). [Doc. 2]. Because the Court GRANTS Plaintiff’s Motion for Leave to Proceed IFP [Doc. 2] and waives the filing fee, the Court must review his Complaint. See U.S.C. § 1915(e). MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS Authority for granting a plaintiff permission to file a lawsuit without prepayment of fees and costs is found in 28 U.S.C. § 1915, which provides as follows: [Generally], any court of the United States 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, by a person who submits an affidavit that includes a statement of all assets such prisoner possesses1 that the person is unable to pay such fees or give security therefor. Such affidavit shall state the nature of the action,

1 “Despite the statute’s use of the phrase ‘prisoner possesses,’ the affidavit requirement applies to all persons requesting leave to proceed [in forma pauperis].” Martinez v. Kristi Kleaners, Inc., 364 F.3d 1305, 1306 n.1 (11th Cir. 2004). defense or appeal and affiant’s belief that the person is entitled to redress.

28 U.S.C. § 1915(a)(1). A plaintiff’s application is sufficient to warrant a waiver of filing fees if it “represents that the litigant, because of his poverty, is unable to pay for the court fees and costs, and to support and provide necessities for himself and his dependents.” Martinez v. Kristi Kleaners, Inc., 364 F.3d 1305, 1307 (11th Cir. 2004). After

reviewing Plaintiff’s application, the Court GRANTS Plaintiff’s Motion for Leave to Proceed In Forma Pauperis [Doc. 2] or, stated differently, grants him IFP status. FRIVOLITY REVIEW

A. Legal Standard Since Plaintiff is proceeding IFP, 28 U.S.C. § 1915(e) requires the Court to review his Complaint to determine whether it is frivolous or malicious or fails to state a claim for which relief may be granted.2 28 U.S.C. § 1915(e)(2)(B)(i)–(ii). The proper contours of

the term “frivolous,” have been defined by the Supreme Court to encompass complaints that, despite their factual allegations and legal conclusions, lack an arguable basis either in law or in fact. Neitzke v Williams, 490 U.S. 319, 325 (1989). These types of

complaints are subject to sua sponte dismissal by a district court. Id. at 324 (noting that dismissals under § 1915(e) “are often made sua sponte prior to the issuance of process,

2 The Eleventh Circuit has determined that “28 U.S.C. § 1915(e), which governs proceedings in forma pauperis generally . . . permits district courts to dismiss a case ‘at any time’ if the complaint ‘fails to state a claim on which relief may be granted.’” Robinson v. United States, 484 F. App’x 421, 422 n.2 (11th Cir. 2012) (per curiam); see also 28 U.S.C. § 1915(e)(2)(B)(ii). so as to spare prospective defendants the inconvenience and expense of answering such complaints[]”).

More specifically, to survive this initial screening, a claim must contain “sufficient factual matter, accepted as true, to state a claim that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Federal Rule of Civil Procedure 12(b)(6)

“authorizes a court to dismiss a claim on the basis of a dispositive issue of law.” Neitzke, 490 U.S. at 326 (citing Hishon v. King & Spalding, 467 U.S. 69, 73 (1984)). Such dismissal procedure—operating on the assumption that the factual allegations in the complaint

are true—streamlines litigation by dispensing with unnecessary discovery and factfinding. Id. “Nothing in Rule 12(b)(6) confines its sweep to claims of law which are obviously unsupportable.” Id. at 327. To the contrary, if it is clear, as a matter of law, that no relief could be granted under “any set of facts that could be proven with the

allegations,” a claim must be dismissed. Id. (quoting Hishon, 467 U.S. at 73). Frivolity review under § 1915(e), on the other hand, has a separate function. Section 1915(e) is designed to discourage the filing of—and waste of judicial and private

resources upon—baseless lawsuits that paying litigants generally do not initiate due to filing costs and the potential threat of sanctions associated with filing such a lawsuit. Id. “To this end, the statute accords judges not only the authority to dismiss a claim based on an indisputably meritless legal theory, but also the unusual power to pierce the veil

of [a] complaint’s factual allegations and dismiss those claims whose factual contentions are clearly baseless.” Id. Even though Rule 12 and § 1915(e) both counsel dismissal and share “considerable common ground” with each other, one dismissal standard does not

invariably encompass the other. Id. at 328. “When a complaint raises an arguable question of law which the district court ultimately finds is correctly resolved against [a] plaintiff, dismissal on Rule 12(b)(6) grounds is appropriate, but dismissal on the basis of

frivolousness is not.” Id. B. Frivolity Review In his Complaint, Plaintiff seeks relief for alleged violations of his “unalienable

rights” by individuals that the Court can only assume are unnamed employees of the state government. [Doc. 1, p. 1]. Plaintiff argues that Defendant has violated his constitutional rights, including those protected under the Fourth, Fifth, Sixth, and Seventh Amendments to the United States Constitution. [Doc. 1, pp. 4-5]. Plaintiff

appears to generally allege that his constitutional rights were violated in connection with a child support order filed in the Superior Court of Clarke County, Georgia, in 2013. [Id.].

Plaintiff’s first issue is that he has named a defendant that does not presently exist by that name. Plaintiff names the “Georgia DHR Services” as the defendant in this action. [Doc. 1]. The Court takes the risk of assuming that Plaintiff is referring to what used to be known as the Georgia Department of Human Resources. However, the

Georgia Department of Human Resources has not existed by that name since 2009. As such, Plaintiff seemingly seeks relief from an agency that no longer exists. Because Plaintiff’s allegations primarily concern issues with his child support obligations, the

Court will hazard a guess that Plaintiff meant, instead, to refer to the Georgia Department of Human Services. Although it is now apparent that Plaintiff has sued the wrong party, the Court may not dismiss his claims for misjoinder alone. See Fed.

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556 U.S. 662 (Supreme Court, 2009)
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DUGGANS v. THE GA DHR SERVICES, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duggans-v-the-ga-dhr-services-gamd-2025.