Goins v. Winkel

CourtDistrict Court, N.D. Ohio
DecidedFebruary 14, 2025
Docket1:24-cv-00653
StatusUnknown

This text of Goins v. Winkel (Goins v. Winkel) 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
Goins v. Winkel, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

JUSTIN GOINS, ) Case No. 1:24-cv-00653 ) Plaintiff, ) Judge J. Philip Calabrese ) v. ) Magistrate Judge ) James E. Grimes, Jr. CORPORAL WINKEL, ) ) Defendant. ) )

OPINION AND ORDER Plaintiff Justin Goins filed suit without a lawyer against a Defendant he identifies only as Corporal Winkel, alleging civil rights violations under the Eighth and Fourteenth Amendments. Though served, Defendant failed to appear or defend against this lawsuit. Nor did any representative appear on his behalf. Plaintiff moves for a default judgment. STATEMENT OF THE FACTS On August 8, 2023, Plaintiff Justin Goins was a pre-trial detainee at the Cuyahoga County jail. (ECF No. 1, PageID #4; ECF No. 1-1, PageID #14.) An officer escorted him to his cell in handcuffs when another inmate allegedly stepped out of a shower and blindsided Mr. Goins, assaulting him. (ECF No. 1-1, PageID #15.) Another officer reported the assault, to which Defendant Corporal Winkel responded. (Id.) Mr. Goins claims that he and the officer who witnessed the assault attempted to explain what happened to Corporal Winkel when he arrived, including that Mr. Goins was in handcuffs at the time of the incident. (Id.) However, Mr. Goins claims that Corporal Winkel “wasn’t trying to hear anything [he had] to say” and tried to force Mr. Goins back into his cell. (Id.) Mr. Goins responded by allegedly

putting his back against the wall and stating that he was “not locking down until [he could] talk to someone.” (Id.) The officer allegedly tried to explain to Corporal Winkel that he did not have to “spray [Mr. Goins] because [he was] secured.” (Id.) Mr. Goins claims that he tried to move out of Corporal Winkel’s reach, which is when Corporal Winkel allegedly sprayed Mr. Goins with mace. (Id.) Mr. Goins filed a grievance with the jail, which he claimed was “investigated

and closed.” (ECF No. 1, PageID #7.) He claimed he tried to appeal the decision, but got no response. (Id.) STATEMENT OF THE CASE Based on this event, on April 11, 2024, Plaintiff filed a pro se complaint against Defendant, raising a claim against him in both his individual and official capacity under 42 U.S.C. § 1983. Specifically, Plaintiff alleged that Defendant violated his rights under the Eighth and Fourteenth Amendments by using excessive force when

Defendant maced Mr. Goins while he was handcuffed. (ECF. No. 1, PageID #3–4.) The record reflects that Plaintiff completed service on Defendant on June 12, 2024. (ECF No. 9.) Defendant failed to respond to Plaintiff’s complaint and has not taken any other action to defend this lawsuit. Nor has anyone done so on his behalf. On November 8, 2024, the Clerk entered default against Defendant under Rule 55(a) of the Federal Rules of Civil Procedure. (ECF No. 10.) On December 13, 2024, Plaintiff moved for a default judgment under Rule 55(b). (ECF. No. 13.) He filed another motion for a default judgment on February 10, 2025. (ECF No. 20.) ANALYSIS

Rule 55 of the Federal Rules of Civil Procedure governs the entry of default and default judgment. “When a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s default.” Fed. R. Civ. P. 55(a). On November 8, 2024, the Clerk entered default against Defendant, who failed to answer, appear, or otherwise defend. (ECF No. 10.)

After entry of default under Rule 55(a), the party seeking relief may apply for a default judgment under Rule 55(b). “An allegation—other than one relating to the amount of damages—is admitted if a responsive pleading is required and the allegation is not denied.” Fed. R. Civ. P. 8(b)(6). In other words, a default on well- pleaded allegations establishes the defendant’s liability, but the plaintiff bears the burden of establishing damages. Flynn v. People’s Choice Home Loan, Inc., 440 F. App’x 452, 457 (6th Cir. 2011) (citing Antoine v. Atlas Turner, Inc., 66 F.3d 105, 110

(6th Cir. 1995)). “Where damages are unliquidated a default admits only the defendant’s liability and the amount of damages must be proved.” Antoine, 66 F.3d at 110. I. Liability Once default is entered, the defaulting party is deemed to have admitted all the well-pleaded factual allegations in the complaint regarding liability, including jurisdictional averments. Ford Motor Co. v. Cross, 441 F. Supp. 2d 837, 846 (E.D. Mich. 2006) (citing Visioneering Constr. v. U.S. Fid. & Guar., 661 F.2d 119, 124 (6th Cir. 1981)); see also Fed. R. Civ. P. 8(b)(6) (“An allegation—other than one relating to the amount of damages—is admitted if a responsive pleading is required and the

allegation is not denied.”). Although the pleadings and documents pro se litigants file are liberally construed and held to less stringent standards than the formal pleadings of lawyers, Martin v. Overton, 391 F.3d 710, 712 (6th Cir. 2004), pro se litigants are not exempt from the requirements of the Federal Rules of Civil Procedure. Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989). Plaintiff filed his complaint asserting claims under 42

U.S.C. § 1983 for violations of the Eighth and Fourteenth Amendments for Defendant’s use of excessive force. However, the Supreme Court has held, and the Sixth Circuit agrees, “that all excessive force claims should be considered under the Fourth Amendment standard.” Adams v. Metiva, 31 F.3d 375, 385 (6th Cir. 1994) (citing Graham v. Connor, 490 U.S. 386, 394–95 (6th Cir. 1989)). Where excessive force claims are brought under Section 1983, the Sixth Circuit embraces a reasonableness standard, which “requires careful attention to the facts and

circumstances of each particular case, including the severity of the crime at issue,” and “whether the suspect poses an immediate threat to the safety of the officers or others.” Id. (quoting Pleasant v. Zamieski, 895 F.2d 272, 276 (6th Cir. 1990)). Although Plaintiff brings his excessive force claim under the Eighth Amendment, the Court liberally construes his claim under the Fourth Amendment instead. Plaintiff alleges that he “wasn’t being a threat” and was handcuffed, so the use of mace amounted to an excessive use of force in violation of his constitutional rights. (ECF. No. 1, PageID #3–5.) By virtue of his default, Defendant has admitted the allegations in the complaint, and those allegations are sufficient to establish

Plaintiff’s claim.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
William Flynn v. People's Choice Home Loans, Inc
440 F. App'x 452 (Sixth Circuit, 2011)
Gene Autrey Adams v. Paul Metiva
31 F.3d 375 (Sixth Circuit, 1994)
Eric Martin v. William Overton
391 F.3d 710 (Sixth Circuit, 2004)
Kelley v. Carr
567 F. Supp. 831 (W.D. Michigan, 1983)
Ford Motor Co. v. Cross
441 F. Supp. 2d 837 (E.D. Michigan, 2006)
Mark Vesligaj v. Michael Peterson
331 F. App'x 351 (Sixth Circuit, 2009)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
Goins v. Winkel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goins-v-winkel-ohnd-2025.