Hairston v. Gallagher

CourtDistrict Court, D. Maryland
DecidedAugust 26, 2025
Docket1:25-cv-02657
StatusUnknown

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

Bluebook
Hairston v. Gallagher, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

ARTHUR HAIRSTON,

Plaintiff,

v. Civil No. 1:25-cv-02657-JRR

JUDGE STEPHANIE A. GALLAGHER, et al.,

Defendants.

MEMORANDUM AND ORDER Plaintiff Arthur Hairston, a self-represented litigant, initiated this action on August 11, 2025, with the filing of his complaint and a Motion for Leave to Proceed In Forma Pauperis (the “Motion”). (ECF No. 6.) Because Plaintiff appears indigent, the Motion (ECF No. 6) will be granted. For the reasons set forth below, however, Plaintiff’s Amended Complaint (ECF No. 7) will be dismissed. Plaintiff’s Amended Complaint (the operative complaint in this action) asserts claims against Defendants Judge Stephanie A. Gallagher, U.S. Attorney Kelly O. Hayes, and Assistant U.S. Attorney Megan L. Micco in their official and individual capacities. (ECF No. 7.) With regard to Judge Gallagher, Plaintiff alleges that Judge Gallagher “violated her oath of office” by failing to “administer justice without respect to persons and do equal right to the poor and to the rich,” “faithfully and impartially discharge and perform all the duties incumbent upon her under the Constitution and laws of the United States,” and “protect [his] constitutionally protected rights.” (ECF No. 7 at pp. 1–2.) As the bases of these claims, he cites 28 U.S.C. § 453, 28 U.S.C. § 1331, and 18 U.S.C. § 242.1 Id. at pp. 2–3.

1 While not the bases of his claims against Judge Gallagher, Plaintiff contends that by the aforementioned alleged violations, Judge Gallagher denied him his rights under 18 U.S.C. § 1035 and the False Claims Act, 31 U.S.C. § 3729. (ECF No. 7 at p. 4.) With regard to Attorneys Hayes and Micco, Plaintiff similarly avers that they violated their oaths of office under 28 U.S.C. § 544, by “failing . . . to follow the [C]onstitution and laws[] of the United States,” and by “not acting rightfully and impartially for the sake of [Plaintiff] as a citizen.” (ECF No. 7 at p. 4.) As the bases of these claims, he cites 28 U.S.C. § 544, “Article III,”

18 U.S.C. § 1035, 31 U.S.C. § 3729, and 18 U.S.C. § 242. Id. at pp. 4–5. Plaintiff initiated this action in forma pauperis pursuant to 28 U.S.C. § 1915(a)(1), which permits a litigant who is indigent to commence an action in this court without prepaying the filing fee. To guard against possible abuses of this privilege, the statute requires dismissal of any claim that is frivolous, malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief.2 28 U.S.C. § 1915(e)(2)(B). Further still, “[f]rivolous complaints are subject to dismissal pursuant to the court’s inherent authority, even when the plaintiff has paid the filing fee.” Smith v. Kagan, 616 F. App’x 90 (4th Cir. 2015); see Chong Su Yi v. Soc. Sec. Admin., 554 F. App’x 247, 248 (4th Cir. 2014) (same); Ross v. Baron, 493 F. App’x 405, 406 (4th Cir. 2012) (same).

Although a complaint need not contain detailed allegations, the facts alleged must be sufficient to raise a right to relief above the speculative level; a complaint must be based on “more than labels and conclusions,” as “‘courts are not bound to accept as true a legal conclusion couched as a factual allegation.’” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). The complaint must contain “enough facts to state a claim to relief that is plausible on its face.” Id. at 570. Once a claim has been stated adequately, it may be supported by showing any set of facts consistent with

2 This court is mindful of its obligation to liberally construe the pleadings of self-represented litigants, such as the instant Complaint. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). In evaluating such a complaint, the factual allegations are assumed to be true. Id. at 93 (citing Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555–56 (2007)). the allegations in the complaint. Id. at 561. Further, under Federal Rule of Civil Procedure 8(a), a pleading which sets forth a claim for relief, shall contain: (1) a short and plain statement of the grounds for the court’s jurisdiction, unless the court already has jurisdiction and the claim needs no new jurisdictional support;

(2) a short and plain statement of the claim showing that the pleader is entitled to relief; and

(3) a demand for the relief sought.

FED. R. CIV. P. 8(a). Each “allegation must be simple, concise, and direct.” FED. R. CIV. P. 8(d)(1). “Threadbare recitals of the elements of a cause of action, supported by mere statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 555). Even construed liberally, Plaintiff’s Amended Complaint fails to state plausible claims for relief for a number of reasons, each of which independently warrants dismissal here. As an initial matter, Plaintiff’s Amended Complaint is devoid of factual allegations, and instead relies entirely on conclusory assertions that Defendants violated his rights. As such, his pleading fails to provide a short and plain statement of his claims showing he is entitled to the relief sought. See FED. R. CIV. P. 8(a). Further, he has not alleged facts to state plausible claims. See Twombly, 550 U.S. at 555, supra. This failure is all the more critical where Plaintiff appears to allege fraud. See FED. R. CIV. P. 9(b) (“In alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake.”) Moreover, Plaintiff’s Amended Complaint relies upon a number of statutes that do not offer a private right of action; and, as to the False Claims Act, the statute does not apply to benefit Plaintiff as he appears to contend. First, Plaintiff invokes 18 U.S.C. § 242 and 18 U.S.C. § 1035— criminal statutes that do not confer a private right of action. See, e.g., Burnett v. Edward A. Garmatz U.S. District Courthouse, No. 25-1068, 2025 WL 1134564, at *3 (D. Md. Apr. 17, 2025) (regarding 18 U.S.C. § 242); Turner v. Beal, No.

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Hairston v. Gallagher, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hairston-v-gallagher-mdd-2025.