Erik Davis v. The City of Selma, et al.

CourtDistrict Court, S.D. Alabama
DecidedJanuary 8, 2026
Docket2:25-cv-00101
StatusUnknown

This text of Erik Davis v. The City of Selma, et al. (Erik Davis v. The City of Selma, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erik Davis v. The City of Selma, et al., (S.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA NORTHERN DIVISION

ERIK DAVIS, * * Plaintiff, * * vs. * CIVIL ACTION NO. 25-00101-KD-B * THE CITY OF SELMA, et al., * * Defendants. *

REPORT AND RECOMMENDATION

This action is before the Court on Defendants the City of Selma, the Selma Police Department, and Officer Joseph Ellis’s motion to dismiss Plaintiff’s amended complaint and memorandum brief in support (Docs. 17, 18). The motion has been referred to the undersigned Magistrate Judge for consideration and recommendation pursuant to 28 U.S.C. § 636(b)(1) and S.D. Ala. GenLR 72(a)(2)(S). Upon consideration of all matters presented, and for the reasons stated herein, the undersigned recommends that Defendants’ motion to dismiss be GRANTED in part and DENIED in part, as set out below. I. BACKGROUND Plaintiff Erik Davis (“Davis”), who is proceeding pro se, commenced this action by filing a complaint in the United States District Court for the Middle District of Alabama. (Doc. 1). This action was subsequently transferred to the United States District Court for the Southern District of Alabama. (Docs. 4, 5). Following transfer, this Court conducted a sua sponte review of Davis’s complaint. In an order dated March 17, 2025, the Court informed Davis that his complaint was an impermissible shotgun pleading that violated federal pleading standards and failed to provide adequate notice of his claims and the factual grounds on

which they were based. (Doc. 6 at 4). The Court explained to Davis that his complaint violated Federal Rule of Civil Procedure 10(b) and the rule against shotgun pleadings because it did not separate his claims into different counts, it did not make clear what claims he was attempting to assert, and it did not specify which factual allegations were intended to support which claims for relief or causes of action. (Id.). The Court informed Davis that his complaint was also a shotgun pleading because it tried to assert multiple claims against multiple defendants but did not specify which of the defendants each claim was brought against, nor did it make clear which defendants’ acts or omissions formed the basis for which claims. (Id. at 4-5). The Court further noted

that the complaint bore hallmarks of a shotgun pleading because it included a number of immaterial facts not obviously connected to any particular cause of action. (Id. at 5). The Court recognized that Davis was trying to assert claims under 42 U.S.C. § 1983 but noted that he had not separated his putative § 1983 claims into different counts as required, nor had he specified the factual basis for each such claim or made clear 2 which claims were asserted against which defendants. (Id.). The Court also explained to Davis that his complaint violated the general rule prohibiting fictitious party pleading in federal court. (Id. at 6-7). Finally, the Court informed Davis that the Selma Police Department was not a proper defendant in this action.

(Id. at 7). The Court struck Davis’s complaint as an impermissible shotgun pleading but granted Davis leave to file an amended complaint that addressed and corrected the noted pleading defects. (Id. at 8). To assist Davis in drafting a complying amended complaint, the Court informed him of the general pleading standards for a complaint in federal court and the more specific requirements to state a claim on which relief may be granted under 42 U.S.C. § 1983. (Id. at 2-3, 9-11). The Court also provided the following instructions to assist Davis in drafting his amended complaint: In drafting his amended complaint, Plaintiff must plead his claims with enough specificity to conform to Rules 8 and 10 of the Federal Rules of Civil Procedure and must address and correct the deficiencies outlined in this order. This includes: (1) identifying his pleading as an amended complaint; (2) naming only proper defendants and omitting purely fictitious defendants; (3) stating his allegations in numbered paragraphs, each limited as far as practicable to a single set of circumstances; (4) stating each cause of action or claim for relief in a separate count, and specifically identifying the legal basis for each cause of action or claim for relief asserted;1 (5) providing the specific

1 The Court informed Davis that if he asserted claims for relief under 42 U.S.C. § 1983 in his amended complaint, he was required

3 factual grounds upon which each cause of action or claim for relief is based, and clearly indicating which facts are intended to support which causes of action or claims for relief; (6) specifying which claims for relief or causes of action are asserted against which defendants, and specifying the conduct that each defendant is alleged to have engaged in with respect to each cause of action or claim for relief asserted against that defendant; and (7) stating the relief he seeks.

(Id. at 8-9). The Court cautioned Davis that if he did not file an amended complaint within the ordered time, or if he filed an amended complaint that failed to address and correct the noted pleading defects, the undersigned would recommend that this action be dismissed. (Id. at 12). Davis did not file an amended complaint within the ordered time, but he subsequently filed a motion for leave to file an amended complaint and a proposed amended complaint with exhibits. (Docs. 10, 10-1, 10-2, 10-3, 10-4). The Court found that Davis’s motion for leave to amend was unnecessary but nevertheless granted the motion and directed the Clerk to docket the proposed amended complaint with exhibits in a new and separate docket entry. (Doc. 11 at 2-3). On May 20, 2025, the Clerk docketed the amended complaint with exhibits. (Docs. 12, 12-1, 12-2, 12-3). The amended complaint docketed by the Clerk is now Davis’s operative pleading in this case.

to “allege separate counts for each claimed constitutional violation.” (Doc. 6 at 9 n.5). 4 On July 14, 2025, Defendants the City of Selma, the Selma Police Department, and Officer Joseph Ellis (collectively, “Defendants”)2 filed the instant motion to dismiss Davis’s amended complaint pursuant to Federal Rule of Civil Procedure 12(b)(6), along with a memorandum brief in support of the motion to dismiss.

(Docs. 17, 18). Defendants argue that the amended complaint is due to be dismissed with prejudice because, like the original complaint, it is a shotgun pleading that fails to comply with federal pleading standards and fails to provide adequate notice of the claims being asserted and the grounds upon which each claim rests. (Doc. 18 at 13, 16). Defendants assert that the amended complaint “is a shotgun pleading of the second type” because “it is replete with conclusory, vague, and immaterial facts not obviously connected to any particular cause of action.” (Id. at 16 (quotation omitted)). Defendants assert that the amended complaint “is also a shotgun pleading of the third type, as it does not separate into a different count each cause of action or

2 Davis’s operative amended complaint names as Defendants the City of Selma, the Selma Police Department, Selma Police Department officer Joseph Ellis, and former Selma Police Department officer Malachai M. Washington. (Doc. 12).

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Bluebook (online)
Erik Davis v. The City of Selma, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/erik-davis-v-the-city-of-selma-et-al-alsd-2026.