Graham v. Internal Revenue Criminal Investigation Unit

CourtDistrict Court, M.D. Florida
DecidedJanuary 2, 2025
Docket5:24-cv-00696
StatusUnknown

This text of Graham v. Internal Revenue Criminal Investigation Unit (Graham v. Internal Revenue Criminal Investigation Unit) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Graham v. Internal Revenue Criminal Investigation Unit, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA OCALA DIVISION

RACHEL REGINA GRAHAM,

Plaintiff,

v. Case No: 5:24-cv-696-MSS-PRL

INTERNAL REVENUE CRIMINAL INVESTIGATION UNIT, JOHN MAND, JANE DOE, and JOHN DOE,

Defendants.

ORDER Plaintiff Rachel Regina Graham (“Plaintiff”), who is proceeding pro se, filed this action against the Internal Revenue Criminal Investigation Unit and various John and Jane Does1 within that unit (collectively, the “Defendants”). (Doc. 1). Plaintiff seeks to proceed in forma pauperis. (Doc. 2). For the reasons explained below, Plaintiff’s motion to proceed in forma pauperis is taken under advisement, and in an abundance of caution, Plaintiff will be given an opportunity to amend the complaint. I. LEGAL STANDARDS An individual may be allowed to proceed in forma pauperis if she declares in an affidavit that she is unable to pay such fees or give security therefor. See 28 U.S.C. § 1915(a)(1). However, before a plaintiff is permitted to proceed in forma pauperis, the Court is obligated to review the complaint to determine whether it is frivolous, malicious, fails to state a claim

1 Plaintiff also sues “John Mand Joe Doe,” but that appears to be a typographical error. (Doc. 1 at p. 3). upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. See id. § 1915(e)(2). If the complaint is deficient, the Court is required to dismiss the suit sua sponte. Id. “A lawsuit is frivolous if the plaintiff’s realistic chances of ultimate success are slight.”

Clark v. Ga. Pardons & Paroles Bd., 915 F.2d 636, 639 (11th Cir. 1990) (internal quotations omitted); see Neitzke v. Williams, 490 U.S. 319, 325 (1989) (stating that an action is frivolous if “it lacks an arguable basis either in law or in fact”); Jackson v. Farmers Ins. Grp./Fire Ins. Exch., 391 F. App’x 854, 856 (11th Cir. 2010) (per curiam) (defining a frivolous case as one containing “clearly baseless” factual allegations or one based on an “indisputably meritless” legal theory) (quoting Carroll v. Gross, 984 F.2d 392, 393 (11th Cir. 1993) (per curiam)). In deciding frivolousness, a court may consider “a litigant's history of bringing unmeritorious litigation.” Bilal v. Driver, 251 F.3d 1346, 1350 (11th Cir. 2001). “Indigence does not create a constitutional right to the expenditure of public funds and

the valuable time of the courts in order to prosecute an action which is totally without merit.” Phillips v. Mashburn, 746 F.2d 782, 785 (11th Cir. 1984) (citing Collins v. Cundy, 603 F.2d 825, 828 (10th Cir. 1979)). In evaluating a complaint under § 1915, a document filed pro se is to be liberally construed. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). Nevertheless, a complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim has facial plausibility when the plaintiff pleads factual content, allowing the court to draw the reasonable inference that the defendant is liable for the alleged misconduct. See id. at 555-56. While Rule 8(a) of the Federal Rules of Civil Procedure does not require detailed factual

allegations, “it demands more than an unadorned, the defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 555). A pleading is insufficient if it offers mere “labels and conclusions” or “a formulaic recitation of the elements of a cause of action.” Twombly, 550 U.S. at 555. Jurisdiction is a threshold issue in any case pending in the United States district court.

Indeed, federal courts are courts of limited jurisdiction, which are “‘empowered to hear only those cases within the judicial power of the United States as defined by Article III of the Constitution,’ and which have been entrusted to them by a jurisdictional grant authorized by Congress.” Univ. of So. Ala. v. Am. Tobacco Co., 168 F.3d 405, 409 (11th Cir. 1999) (quoting Taylor v. Appleton, 30 F.3d 1365, 1367 (11th Cir. 1994)). “[A] court must zealously insure that jurisdiction exists over a case, and should itself raise the question of subject matter jurisdiction at any point in the litigation where a doubt about jurisdiction arises.” Smith v. GTE Corp., 236 F.3d 1292, 1299 (11th Cir. 2001); see Fitzgerald v. Seaboard Sys. R.R., 760 F.2d 1249, 1251 (11th Cir. 1985) (“A federal court not only has the power but also the obligation at any time to

inquire into jurisdiction whenever the possibility that jurisdiction does not exist arises.”). This inquiry should be done at the earliest stage in the proceedings and sua sponte whenever subject matter jurisdiction may be lacking. See Univ. of So. Ala., 168 F.3d at 410; Fitzgerald, 760 F.2d at 1251. “[O]nce a court determines that there has been no [jurisdictional] grant that covers a particular case, the court's sole remaining act is to dismiss the case for lack of jurisdiction.” Morrison v. Allstate Indem. Co., 228 F.3d 1255, 1261 (11th Cir. 2000). II. DISCUSSION Plaintiff uses the standard form entitled “Complaint and Request for Injunction” as her complaint, and included in Plaintiff’s filing is the first page of the “Complaint for Violation of Civil Rights (Non-Prisoner)” form. (Doc. 1). Plaintiff’s allegations in her complaint are

almost entirely incomprehensible and resemble paranoid delusions. As best can be discerned from her sparse and vague allegations, it appears the Plaintiff is contesting the actions of the Internal Revenue Criminal Investigation Unit and individuals in that unit who were involved in an investigation of the Plaintiff. In a conclusory fashion and without specifying any factual details, Plaintiff asserts that the “investigation has been alleg[ed]ly evident for a[n] excessive number of years, even to present date that has resulted in irrepa[rable] personal injuries and gross punitive damages that far exceeds $75,000.” (Id. at p. 5). She further alleges that “as a result[] of excessive years of on-going [sic] events, [she] ha[s] excessive irrepa[rable] personal damages to [her] entire state of being that ranges from the trauma, to distresses both physical

and emotional[,]” “pain in [her] body [that] is unb[eara]able,” she “lost everything[,]” “ended up without transportation, homeless, unemployed[,]” and “left for dead[.]” (Id. at p. 6).

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

Related

University of South Alabama v. American Tobacco Co.
168 F.3d 405 (Eleventh Circuit, 1999)
Bilal v. Driver
251 F.3d 1346 (Eleventh Circuit, 2001)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jackson v. Farmers Insurance Group/Fire Insurance Exchange
391 F. App'x 854 (Eleventh Circuit, 2010)
Taylor v. Appleton
30 F.3d 1365 (Eleventh Circuit, 1994)
Phillips v. Mashburn
746 F.2d 782 (Eleventh Circuit, 1984)
Fitzgerald v. Seaboard System Railroad
760 F.2d 1249 (Eleventh Circuit, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
Graham v. Internal Revenue Criminal Investigation Unit, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graham-v-internal-revenue-criminal-investigation-unit-flmd-2025.