GILBERT v. MAINE DEPARTMENT OF HEALTH AND HUMAN SERVICES

District Court, D. Maine·Decided December 30, 2024·No. 2:24-cv-00371·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

DUSTIN GRAHAM GILBERT, ) ) Plaintiff ) ) v. ) 2:24-cv-00371-JAW ) MAINE DEPARTMENT OF ) HEALTH AND HUMAN SERVICES, ) ) Defendant )

ORDER ON RECOMMENDED DECISION AND OBJECTION

The court affirms in part and reverses in part an order issued by a federal magistrate judge recommending the court dismiss a claim alleging the Maine Department of Health and Human Services deprived a patient, then a resident at a state psychiatric center, of his constitutional right to vote. The court dismisses the claims brought pursuant to the Fifteenth Amendment, Article I of the U.S. Constitution, and the employment provisions of the Americans with Disabilities Act (ADA) but concludes the plaintiff should be allowed to proceed with his claim based on an alleged violation of the voting rights provisions of the ADA. I. BACKGROUND On November 1, 2024, Dustin Graham Gilbert, acting pro se, filed a complaint against the Maine Department of Health and Human Services (Maine DHHS) pursuant to the Fifteenth Amendment to the United States Constitution, alleging he was deprived of his right to vote while in the care of a psychiatric hospital. Compl. at 4, 7 (ECF No. 1). He specifically claims that while in civil inpatient residence at Riverview Psychiatric Center, he requested but never received a ballot for the 2022 election.1 Id. at 7. On December 9, 2024, the United States Magistrate Judge recommended the

Court dismiss Mr. Gilbert’s complaint. Recommended Decision after Rev. of Pl.’s Compl. (ECF No. 9) (Recommended Decision). Mr. Gilbert objected to the Recommended Decision on December 19, 2024. Obj. to Rep. and Recommended Decision (ECF No. 10) (Pl.’s Obj.). On December 23, 2024, after the order was taken under advisement, Mr. Gilbert filed additional attachments in support of his objection. Additional Attachs. (ECF No. 11).

II. THE MAGISTRATE JUDGE’S RECOMMENDED DECISION Pursuant to the screening provisions of 28 U.S.C. § 1915(e)(2), the Magistrate Judge recommends the Court dismiss Mr. Gilbert’s complaint brought against Maine DHHS for several reasons. First, the Magistrate Judge concludes dismissal is appropriate because the Fifteenth Amendment promises that the “right of citizens of the United States to vote shall not be denied or abridged . . . on account of race, color, or previous condition of servitude,” Recommended Decision at 4 n.2 (quoting U.S.

CONST. amend. XV), and Mr. Gilbert “provides no facts that suggest his race was in any way relevant to his claim.” Id. at 3-4.

1 The Magistrate Judge’s Recommended Decision addressing Mr. Gilbert’s complaint correctly observes that the Plaintiff had not specified for which election in 2022 he requested a ballot. Recommended Decision after Rev. of Pl.’s Compl. at 2 n.1 (ECF No. 9) (Recommended Decision). The Magistrate Judge assumed that Mr. Gilbert was referring to the 2022 election. Id. In his objection, Mr. Gilbert confirmed he was a resident at Riverview at the time of the 2022 election. Obj. to Rep. and Recommended Decision at 1 (ECF No. 10) (Pl.’s Obj.). (“When I was at R[i]verview is roughly stated as the 2022 election and that should provide enough for the Magistrate to know. It was October/November [. . .] which I planned on providing exact dates later”). Based on Mr. Gilbert’s clarification, the Court concludes that he has been referring to the November 2022 election. Second, the Magistrate Judge recommends dismissal because the complaint provides only limited facts in support of an entitlement to relief: “Plaintiff asserts only that (1) he wrote his name on a sign-up sheet, (2) he asked ‘staff’ for his ballot,

and (3) he did not receive a ballot.” Id. at 3. “Without information regarding the circumstances of Plaintiff’s stay at Riverview or the timing and nature of his efforts to vote,” the Magistrate Judge determines that “a factfinder could not plausibly infer that his inability to vote was due to a staff member intentionally preventing him from obtaining and casting a ballot,” such that “the factual content of the complaint is inadequate to move a discernible legal claim ‘across the line from conceivable to

plausible’ entitlement to relief.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009)). Third, the Magistrate Judge concludes that this absence of factual detail is especially problematic for the present claim because the Plaintiff seeks an award of monetary damages against Maine DHHS, relief typically barred under the Eleventh Amendment. Id. at 4-5. III. DUSTIN GILBERT’S OBJECTION AND ADDITIONAL ATTACHMENTS

A. Dustin Gilbert’s Objection to the Recommended Decision Mr. Gilbert objects to the Magistrate Judge’s Recommended Decision. First, he says, he brought his claim pursuant to the Fifteenth Amendment because “the form asked for an Amendment rather than an Article,” and “[he] will amend here if citing an Article is allowed, that Article 1 of the U.S. Constitution was violated by Riverview staff.” Pl.’s Obj. at 1. Second, Mr. Gilbert says the Magistrate Judge’s questions as to why he was at Riverview are “irrelevant and unnecessary.” Id. In response to the Magistrate Judge’s discussion of the lack of relevant information, Mr. Gilbert additionally says “[he] spoke to everyone [he] could see behind the huge desk

on the unit, and those people are ‘mental health workers’ . . .. [he] think[s] everyone on the unit and all the staff knew I didn’t have my ballot before the election.” Id. He alleges further that he contacted several staff about obtaining a ballot “well in advance of the election.” Id. In conclusion he avers “[his] statement of what happened can be discovered by a factfinder and moves a discernable legal claim ‘across the line from conceivable to plausible’ entitlement to relief.” Id. Third, Mr.

Gilbert tells the Court he is a “disabled U.S. citizen collecting SSDI with numerous diagnos[es] mostly dealing with BiPolar, Schizoaffective Disorder, PTSD, Traumatic Brain Injuries, Insomnia and mania.” Id. at 2. He argues “42 U.S.C. [§] 12202 states that states are not immune from lawsuits in federal or state court for [ADA] violations,” and “not getting [him] [his] ballot . . . violated the ADA too.” Id. Mr. Gilbert concludes his objection by reasserting that these violations entitle him to $3,000,000 in punitive damages. Id.

B. Dustin Gilbert’s Additional Attachments On December 23, 2024, Mr. Gilbert filed a memorandum as an additional attachment to his objection. Additional Attachs. The memorandum says, in its entirety, “I have obtained the grievance proving Riverview failed to get me my ballot (by Riverview’s own admission) and the staff I dealt with as a whole are at fault. Riverview Advocates’ office provided the grievance.” Id. at 1 (emphasis in original). He also informs the Court in a postscript note that he has “received a replica of the sign-up sheet.” Id. IV. LEGAL STANDARD

The Court reviews the Magistrate Judge’s order for clear errors or holdings contrary to law. See 28 U.S.C. § 636(b)(1)(A) (“A judge of the court may reconsider any pretrial matter [designated to a magistrate judge] where it has been shown that the [magistrate judge’s] order is clearly erroneous or contrary to law”); FED. R. CIV. P. 72(a) (“The district judge in the case must consider timely objections and modify or set aside any part of the order that is clearly erroneous or is contrary to law”).

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