Haoyu Wang v. Matthew Dumont et al.

CourtDistrict Court, D. Utah
DecidedMay 15, 2026
Docket2:26-cv-00141
StatusUnknown

This text of Haoyu Wang v. Matthew Dumont et al. (Haoyu Wang v. Matthew Dumont et al.) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haoyu Wang v. Matthew Dumont et al., (D. Utah 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

HAOYU WANG, MEMORANDUM DECISION AND ORDER TO CURE Plaintiff, DEFICIENT COMPLAINT

v. Case No. 2:26-CV-141-HCN MATTHEW DUMONT et al., Defendants. Howard C. Nielson, Jr. United States District Judge

Plaintiff Haoyu Wang, a Salt Lake County pretrial detainee, brought this pro se civil- rights action under 42 U.S.C. § 1983. Having now screened the Complaint under its statutory review function, see 28 U.S.C. § 1915A,1 the court orders the Plaintiff to file an amended complaint that cures the deficiencies identified in this order if he would like to further pursue his claims. A. COMPLAINT’S DEFICIENCIES The Complaint:

1 The screening statute reads: (a) Screening.--The court shall review . . . a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. (b) Grounds for dismissal.--On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint-- (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A. 1. may improperly allege civil-rights violations on a respondeat superior theory. (See below.) 2. generally does not affirmatively link one or more specific named defendant(s) to each element of each alleged civil-rights violation. (See below.) 3. does not concisely link each element of the claim of improper medical treatment to each individually named defendant. (See below.) 4. may reflect a misunderstanding of the difference between suing defendants in their individual or official capacities. (See below.) 5. fails to recognize the principles that govern local governmental entities’ liability under federal civil-rights law. (See below.) 6. does not adequately link each element of a retaliation claim, such as actual or threatened retaliatory action that had a tangible effect on the Plaintiff, to one or more specific named defendant(s). (See below.) 7. may inappropriately allege civil-rights violations based on the denial of grievances. See Gallagher v. Shelton, 587 F.3d 1063, 1069 (10th Cir. 2009). 8. may inappropriately allege a constitutional right to a grievance process. See Boyd v. Werholtz, 443 F. App’x 331, 332 (10th Cir. 2011) (unpublished) (“[T]here is no independent constitutional right to state administrative grievance procedures. Nor does the state’s voluntary provision of administrative grievance process create a liberty interest in that process.”); Dixon v. Bishop, No. CV TDC-19-740, 2020 U.S. Dist. LEXIS 41678, at *20 (D. Md. Mar. 11, 2020) (“[P]risons do not create a liberty interest protected by the Due Process Clause when they adopt administrative mechanisms for hearing and deciding inmate complaints[;] any failure to abide by the administrative remedy procedure or to process [grievances] in a certain way does not create a constitutional claim.”). 9. does not adequately link each element of a legal-access claim to one or more specific named defendant(s). (See below.) 10. raises issues of classification change/programming in way that does not support a cause of action. (See below.) 11. raises an issue of mail interference that lacks enough supportive factual allegations to state a cause of action. (See below.) 12. appears to assert claims based on current confinement; the complaint, however, appears not to have been submitted using legal help Plaintiff is constitutionally entitled to by his institution. See Lewis v. Casey, 518 U.S. 343, 356 (1996) (requiring prisoners be given “’adequate law libraries or adequate assistance from persons trained in the law’ . . . to ensure that inmates . . . have a reasonably adequate opportunity to file nonfrivolous legal claims challenging their convictions or conditions of confinement”) (quoting Bounds v. Smith, 430 U.S. 817, 828 (1977) (emphasis added)). 13. possibly raises issues, such as an alleged deprivation of right to counsel, that relate to underlying state criminal charges and thus must be raised in the state court where these charges are pending. See Sweeten v. Sneddon, 463 F.2d 713, 715 (10th Cir. 1972). B. GUIDANCE FOR PLAINTIFF Federal Rule of Civil Procedure 8 requires a complaint to contain “(1) a short and plain statement of the grounds for the court’s jurisdiction . . .; (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.” These requirements are intended to ensure “that defendants enjoy fair notice of what the claims against them are and the grounds upon which they rest.” TV Commc’ns Network, Inc. v ESPN, Inc., 767 F. Supp. 1062, 1069 (D. Colo. 1991). Pro se litigants are not excused from meeting these minimal pleading requirements. “This is so because a pro se plaintiff requires no special legal training to recount the facts surrounding his alleged injury, and he must provide such facts if the court is to determine whether he makes out a claim on which relief can be granted.” Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir.

1991). Moreover, it is improper for the court “to assume the role of advocate for a pro se litigant.” Id. Thus, the court cannot “supply additional facts, [or] construct a legal theory for plaintiff that assumes facts that have not been pleaded.” Dunn v. White, 880 F.2d 1188, 1197 (10th Cir. 1989). The Plaintiff should consider these points before filing an amended complaint: 1. The revised complaint must stand entirely on its own and shall not refer to, or incorporate by reference, any part of the original complaint(s). See Murray v. Archambo, 132 F.3d 609, 612 (10th Cir. 1998) (stating that an amended complaint supersedes the original). Also, the Plaintiff may not add anything to the amended complaint after it is filed without moving for leave to amend. See Fed. R. Civ. P. 15. 2. Each defendant must be named in the complaint’s caption, listed in the section of the complaint setting forth names of each defendant, and affirmatively linked to applicable claims within the “cause of action” section of the complaint. 3. The complaint must clearly state what each individual defendant—typically, a named government employee—did to violate the Plaintiff’s civil rights. See Bennett v. Passic, 545 F.2d 1260, 1262–63 (10th Cir. 1976) (stating that personal participation of each named defendant is an essential allegation in a civil-rights action). “To state a claim, a complaint must ‘make clear exactly who is alleged to have done what to whom.’” Stone v. Albert, 338 F. App’x 757, 759 (10th Cir. 2009) (unpublished) (cleaned up). The Plaintiff should also include, as much as possible, specific dates—or at least estimates—of when alleged constitutional violations

occurred. 4. Each cause of action, together with the facts and citations that directly support it, should be stated separately. The Plaintiff should be as brief as possible while still using enough words to fully explain the “who,” “what,” “where,” “when,” and “why” of each claim. Robbins v. Oklahoma, 519 F.3d 1242, 1248 (10th Cir. 2008) (“The [Bell Atlantic Corp.

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