Eric C. Reyes v. Brett Skidmore et al.

District Court, D. Utah·Decided July 20, 2026·No. 2:25-cv-01160·Unknown

Opinion

THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

ERIC C. REYES,

MEMORANDUM DECISION Plaintiff, AND ORDER TO CURE DEFICIENT COMPLAINT v. Case No. 2:25-CV-1160-TS BRETT SKIDMORE et al., District Judge Ted Stewart

Defendants.

Plaintiff Eric C. Reyes, acting pro se, brought this civil-rights action, see 42 U.S.C.S. § 1983 (2026).1 Having screened the Complaint, Dkt. No. 1, under its statutory review function, 28 U.S.C.S. § 1915A (2026),2 the Court now orders Plaintiff to file an amended complaint curing deficiencies if he would like to further pursue claims.

1The federal statute creating a "civil action for deprivation of rights" reads, in pertinent part: Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory . . ., subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. 42 U.S.C.S. § 1983 (2026).

2 The screening statute reads: (a) Screening.--The court shall review . . . a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. (b) Grounds for dismissal.--On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint-- (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or A. COMPLAINT'S DEFICIENCIES The Complaint: 1. appears to name Salt Lake Police Department as a defendant, when police departments "are not legally suable entities." Lindsey v. Thomson, 275 Fed. App'x. 744, 747 (10th Cir. 2007).

2. possibly improperly alleges civil-rights violations on a respondeat superior theory. (See below.)

3. generally does not properly affirmatively link an individual named defendant to each element of each alleged civil-rights violation. (See below.)

4. does not give enough details--like descriptions, dates and of interactions, etc.--about any possible unknown defendants, to help the Court try to seek waiver of service from them.

5. does not adequately link each element of a due-process claim to specific named defendant(s). See Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 542 (1985) ("An essential principle of due process is that a deprivation of life, liberty, or property be preceded by notice and opportunity for hearing appropriate to the nature of the case." (cleaned up)).

6. seeks that his sentence be vacated, a remedy available only in a habeas or post- conviction petition. See Rhodes v. Hannigan, 12 F.3d 989, 991 (10th Cir. 1993) (explaining habeas-corpus proceeding "attacks the fact or duration of a prisoner's confinement and seeks the remedy of immediate release or a shortened period of confinement," while "civil rights action . . . attacks the conditions of the prisoner's confinement and requests monetary compensation for such conditions") (citation omitted)).

7. asserts claims attacking the validity of Plaintiff's incarceration, which should be timely exhausted in the state-court system before being brought in a federal habeas-corpus petition, not a civil-rights complaint.

8. improperly names Plaintiff's public defender as a defendant, when such attorneys are not state actors under § 1983. (See below.)

9. needs clarification as to what constitutes a cause of action under the Americans with Disabilities Act (ADA). See 42 U.S.C.S. §§ 12101-12213 (2026) (See below.)

(2) seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C.S. § 1915A (2026). 10. alleges possible constitutional violations resulting in injuries appearing to be prohibited by 42 U.S.C.S. § 1997e(e) (2026), which reads, "No Federal civil action may be brought by a prisoner . . . for mental or emotional injury suffered while in custody without a prior showing of a physical injury or the commission of a sexual act."

11. does not concisely link each element of the claim of intentional infliction of emotional distress to individually named defendant(s).3 (See below.)

12. does not concisely link each element of the claim of improper medical treatment to each individually named defendant. (See below.)

13. does not evince appropriate understanding of how a conspiracy claim under 42 U.S.C.S. § 1985 (2026) works. (See below.)

14. alleges conspiracy claims that are too vague. (See below.)

15. does not evince appropriate understanding of how a claim under the Emergency Medical Treatment and Labor Act (EMTALA) works, 42 U.S.C.S. § 1395dd (2026). (See below.)

16. perhaps tries to bring an equal-protection claim, but does not adequately link each element of an equal-protection claim to specific named defendant(s). See Hale v. Fed. Bureau of Prisons, 759 F. App'x 741, 752 (10th Cir. 2019) (explaining that--to state equal-protection claim- -plaintiff must allege facts showing (a) prison officials treated him differently from similarly situated inmates and (b) disparate treatment was not reasonably related to penological interests).

17. inappropriately suggests a claim under "HIPPA." (See below.)

18. under Heck, inappropriately asks for a stay of these proceedings. (See below.)

19. has claims apparently based on current confinement; however, the complaint appears not to have been drafted using legal help Plaintiff is constitutionally entitled to by his institution- -e.g., contract attorneys. See Lewis v. Casey, 518 U.S. 343, 356 (1996) (requiring prisoners be given "adequate law libraries or adequate assistance from persons trained in the law . . . to ensure that inmates . . . have a reasonably adequate opportunity to file nonfrivolous legal claims challenging their convictions or conditions of confinement") (citation modified).

3Plaintiff should keep in mind that, if he brings state-law claims, the Court may take jurisdiction over such claims only as a matter of "pendent jurisdiction," which allows "district courts to hear [state-law] claims that form 'part of the same case or controversy' as the claims on which original federal jurisdiction is based." Thornton v. GEO Grp., Inc. No. CV 14-893 MCA/CG, 2016 U.S. Dist. LEXIS 140710, at 38-39 (D.N.M. May 16, 2016); Estate of Martinez v. Taylor, 176 F. Supp. 3d 1217, 1232 (D. Colo. 2016). Thus, if all Plaintiff's "federal-law claims are eliminated before trial, the balance of factors to be considered under the pendent jurisdiction doctrine--judicial economy, convenience, fairness, and comity--will point toward declining to exercise jurisdiction over the remaining state-law claims." Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343, 350 n.7 (1988). B. GUIDANCE FOR PLAINTIFF Rule 8 of the Federal Rules of Civil Procedure requires a complaint to contain "(1) a short and plain statement of the grounds for the court's jurisdiction . .

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Eric C. Reyes v. Brett Skidmore et al., (D. Utah 2026).

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