Felder v. Ohio Department of Rehabilitation and Correction

CourtDistrict Court, N.D. Ohio
DecidedMarch 20, 2025
Docket1:25-cv-00123
StatusUnknown

This text of Felder v. Ohio Department of Rehabilitation and Correction (Felder v. Ohio Department of Rehabilitation and Correction) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Felder v. Ohio Department of Rehabilitation and Correction, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION KEVIN FELDER ) CASE NO. 1:25 CV 00123 ) Plaintiff, ) ) v. ) JUDGE DONALD C. NUGENT ) OHIO DEPARTMENT OF ) REHABILITATION AND CORRECTION ) M EMORANDUM OPINION ) AND ORDER Defendant. )

I. Introduction Pro se plaintiff Kevin Felder filed this in forma pauperis action, presumably under 42 U.S.C. §1983, against the Ohio Department of Rehabilitation and Correction (“ODRC”). (Doc. No. 1). In the Civil Cover Sheet attached to his complaint, Plaintiff alleges “errors in administration” as his cause of action. (Doc. No. 1-1). In his brief complaint, Plaintiff appears to allege that Defendant made an error on his release date. He claims that he prepared to leave confinement by giving away his property and informing his family, but when “APA arrived, they [canceled] my release because of legislature the prison was not aware of due to an error [in] misreading memos.” (Doc. No. 1 at 3). He claims this error caused him embarrassment and emotional pain and anguish. And for relief, he requests “$500.000.” II. Standard of Review Plaintiff filed an application to proceed in forma pauperis (Doc. No. 2). The Court grants that application. Pro se pleadings are liberally construed. Boag v. MacDougall, 454 U.S. 364, 365, 102 S. Ct. 700, 70 L. Ed. 2d 551 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972). The district court, however, is required to dismiss an in forma pauperis action under 28 U.S.C. § 1915(e) if it fails to state a claim upon which relief can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319, 328, 109 S. Ct. 1827, 104 L. Ed. 2d 338 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990);

Sistrunk v. City of Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are clearly baseless. Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007). Under Federal Rule of Civil Procedure 8(a)(2), a pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009). The factual allegations in the pleading

must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the complaint are true. Twombly, 550 U.S. at 555. The plaintiff is not required to include detailed factual allegations, but he or she must provide more than “an unadorned, the defendant unlawfully harmed me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. The Court is “not bound to accept as true a legal conclusion couched as a factual allegation.” Papasan v. Allain, 478 U.S. 265, 286, 106 S. Ct. 2932, 92 L. Ed. 2d 209 (1986). In reviewing a complaint, the Court must construe the pleading in the light most favorable to the plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.

-2- 1998). III. Discussion As an initial matter, the complaint consists only of bare, conclusory assertions, providing no facts upon which a court could find Defendant engaged in any wrongdoing. The Court recognizes that pro se pleadings are held to a less stringent standard than formal pleadings drafted by lawyers. El Bey v. Roop, 530 F.3d 407, 413 (6th Cir. 2008).

However, the “lenient treatment generally accorded to pro se litigants has limits.” Pilgrim v. Littlefield, 92 F.3d 413, 416 (6th Cir. 1996). Liberal construction for pro se litigants does not “abrogate basic pleading requirements.” Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989). The Court is not required to conjure unpleaded facts or construct claims against defendants on behalf of a pro se plaintiff. See Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985) (District courts are not required to conjure up questions never squarely presented to them or to construct full claims from sentence fragments. To do so would “require ... [the courts] to explore exhaustively all potential claims of a pro se plaintiff ... [and] would ... transform the district court

from its legitimate advisory role to the improper role of an advocate seeking out the strongest arguments and most successful strategies for a party.”) (citation omitted). Although specific facts are not required, to meet the basic minimum notice pleading requirements of Rule 8 of the Federal Rules of Civil Procedure, Plaintiff’s complaint must give the defendants fair notice of what the plaintiff’s legal claims are and the factual grounds on which they rest. See Bassett v. Nat’l Collegiate Ath. Ass’n, 528 F.3d 426, 437 (6th Cir. 2008); see also Scheid v. Fanny Farmer Candy Shops, Inc., 859 F.2d 434, 437 (6th Cir. 1988) (all complaints must contain either direct or inferential allegations respecting all material elements of some viable legal theory to satisfy

federal notice pleading requirements) (citations omitted). -3- Here, Plaintiff’s complaint, even liberally construed, fails to meet the most basic pleading standard, as his pleading fails to set forth “a short and plain statement of [any] claim showing that [Plaintiff] is entitled to relief[.]” Fed. R. Civ. P. 8(a)(2). Plaintiff’s complaint is almost completely devoid of facts. Additionally, the complaint fails to assert a cognizable claim within the jurisdiction of this Court based on recognized legal authority, and the Court finds there is no cause of action readily identifiable in the complaint. Plaintiff’s pleading, rather, is nothing more

than a mere “unadorned, the defendant unlawfully harmed me accusation.” Iqbal, 556 U.S.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Boag v. MacDougall
454 U.S. 364 (Supreme Court, 1982)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Vivian J. Scheid v. Fanny Farmer Candy Shops, Inc.
859 F.2d 434 (Sixth Circuit, 1988)
Torrance Pilgrim v. John Littlefield
92 F.3d 413 (Sixth Circuit, 1996)
El Bey v. Roop
530 F.3d 407 (Sixth Circuit, 2008)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Frazier v. State of Michigan
41 F. App'x 762 (Sixth Circuit, 2002)
Gilmore v. Corrections Corp.
92 F. App'x 188 (Sixth Circuit, 2004)

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Felder v. Ohio Department of Rehabilitation and Correction, Counsel Stack Legal Research, https://law.counselstack.com/opinion/felder-v-ohio-department-of-rehabilitation-and-correction-ohnd-2025.