Gautam v. City of Sunrise

CourtDistrict Court, S.D. Florida
DecidedMay 2, 2025
Docket0:25-cv-60841
StatusUnknown

This text of Gautam v. City of Sunrise (Gautam v. City of Sunrise) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gautam v. City of Sunrise, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 25-CV-60841-STRAUSS

NIHAL MICHAEL GAUTAM,

Plaintiff, v.

CITY OF SUNRISE, et al.,

Defendants. /

ORDER THIS MATTER came before the Court upon pro se Plaintiff’s Motion to proceed In Forma Pauperis (“Motion”). [DE 3]. Plaintiff’s Motion is insufficient for several reasons more fully explained below. Additionally, Plaintiff’s Complaint contains several deficiencies which require Plaintiff to file an amended complaint. Therefore, Plaintiff’s motion is denied without prejudice. If Plaintiff wishes to proceed in forma pauperis, then Plaintiff may renew his motion by refiling this District’s in forma pauperis application along with filing an amended complaint that addresses the deficiencies described below. BACKGROUND Plaintiff filed his Complaint against Defendants on April 29, 2025. [DE 1]. He purports to bring a 42 U.S.C. § 1983 civil rights claim, a Florida Public Records Act claim, a RICO claim under 18 U.S.C. § 1961, an abuse of process claim, and an intentional infliction of emotional distress claim. Id. at 3.1 Plaintiff alleges that he “was arrested without probable cause and physically mistreated,” and “[o]fficers took his child and dogs, erased booking details, and denied

1 Though Plaintiff lists five causes of action in his Complaint, his Civil Cover Sheet only checks one box, Racketeer Influenced and Corrupt Organizations. [DE 1–1] at 1. access to public records for 45+ days.” [DE 1] at 2. Plaintiff further alleges that his public records request from March 2025 remains unanswered, there is “[i]nternal misconduct covered up,” and there is a “[p]attern of racketeering include[ing] civil asset forfeiture abuse, pension fraud, suppression of IA reports, and retaliation.” Id. at 3. LEGAL STANDARD

Pursuant to 28 U.S.C. § 1915, the Court may, upon a finding of indigency, authorize the commencement of an action without requiring the prepayment of fees or security. 28 U.S.C. § 1915(a)(1). The granting of a motion to proceed in forma pauperis is discretionary. Pace v. Evans, 709 F.2d 1428, 1429 (11th Cir. 1983). “When considering a motion filed under Section 1915(a), ‘[t]he only determination to be made by the court . . . is whether the statements in the affidavit satisfy the requirement of poverty.’” Raftery v. Vt. Student Assistance Corp., 2016 WL 11579801, at *1 (M.D. Fla. Feb. 17, 2016) (quoting Martinez v. Kristi Kleaners, Inc., 364 F.3d 1305, 1307 (11th Cir. 2004)). “[A]n affidavit will be held sufficient 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, 364 F.3d at 1307. “The Department of Health and Human Services (HHS) poverty guidelines2 are central to an assessment of an applicant’s poverty.” Ryan v. Comm’r of Soc. Sec., No. 16-CV-61716, 2016 WL 10953761, at *1 (S.D. Fla. July 20, 2016) (citations omitted). A plaintiff, however, need not be “absolutely destitute.” Martinez, 364 F.3d at 1307. Indeed, the court must compare “the applicant’s assets and liabilities in order to determine whether he has satisfied the poverty requirement.” Thomas v. Chattahoochee Judicial Circuit, 574 F. App’x 916, 917 (11th Cir. 2014).

2 See HHS Poverty Guidelines for 2025, available at https://aspe.hhs.gov/poverty-guidelines. Additionally, under 28 U.S.C. § 1915, if a court determines that the case is frivolous or fails to state a claim on which relief may be granted, then the court “shall dismiss the case at any time.” 28 U.S.C. § 1915(e). Although Federal Rule of Civil Procedure 8(a) does not require “detailed factual allegations,” it does require “more than labels and conclusions”; a “formulaic recitation of the cause of action will not do.” Bell Atl. Corp v. Twombly, 550 U.S. 544, 555 (2007).

“Factual allegations must be enough to raise a right to relief above the speculative level” and must be sufficient “to state a claim for relief that is plausible on its face.” Id. at 555, 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When a plaintiff is proceeding pro se, the Court must liberally construe the pro se pleadings and hold them to “less stringent standards” than pleadings drafted by attorneys. Bilal v. Geo Care, LLC, 981 F.3d 903, 911 (11th Cir. 2020). “Yet even in the case of pro se litigants this leniency does not give a court license to serve as de facto counsel for a party, or to rewrite an otherwise deficient pleading in order to sustain an action.” Campbell v. Air

Jamaica Ltd., 760 F.3d 1165, 1168–69 (11th Cir. 2014). ANALYSIS Plaintiff’s Motion is deficient for several reasons. First, Plaintiff fails to list any of his assets. See [DE 3] at 2. Second, Plaintiff fails to list “[a]ny housing, transportation, utilities, or loan payments, or other regular monthly expenses.” Id. Finally, Plaintiff fails to list “[a]ny debts or financial obligations” he has. Id. Instead, Plaintiff drew a checkmark or a line on each of the above questions. Id. Without answers to these questions (i.e., what Plaintiff’s assets and liabilities are), the Court cannot determine whether Plaintiff is unable to pay for the court fees and costs, and to support and provide necessities for himself and his dependents (if any). As to Plaintiff’s Complaint, Plaintiff fails to adequately allege any specific facts from which the Court could reasonably infer Plaintiff has stated plausible claims or that would give Defendants reasonable notice of what those claims are. Plaintiff does not comply with the pleading requirements of Federal Rules of Civil Procedure 8 and 10. According to Federal Rule of Civil Procedure 8, a complaint must contain “a short and plain statement of the claim showing that the

pleader is entitled to relief,” and “[e]ach allegation must be simple, concise, and direct.” Fed. R. Civ. P. 8(a)(2), (d)(1). Rule 10 further expands on pleading requirements and requires the pleader to state its claims “in numbered paragraphs, each limited as far as practicable to a single set of circumstances.” Fed. R. Civ. P. 10(b).

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Related

Evelyn Martinez v. Kristi Kleaners, Inc.
364 F.3d 1305 (Eleventh Circuit, 2004)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Charles Edward Pace v. David Evans
709 F.2d 1428 (Eleventh Circuit, 1983)
Allan Campbell v. Air Jamaica LTD
760 F.3d 1165 (Eleventh Circuit, 2014)
James R. Thomas, Jr. v. Chattahoochee Judicial Circuit
574 F. App'x 916 (Eleventh Circuit, 2014)
Damene W. Woldeab v. DeKalb County Board of Education
885 F.3d 1289 (Eleventh Circuit, 2018)
Charles Silberman v. Miami Dade Transit
927 F.3d 1123 (Eleventh Circuit, 2019)
Jamaal Ali Bilal v. Geo Care, LLC
981 F.3d 903 (Eleventh Circuit, 2020)

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