Harris v. Cunningham

CourtDistrict Court, M.D. Tennessee
DecidedOctober 9, 2025
Docket2:24-cv-00032
StatusUnknown

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

Bluebook
Harris v. Cunningham, (M.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NORTHEASTERN DIVISION COREY HARRIS, # 449257, ) ) Plaintiff, ) ) v. ) No. 2:24-cv-00032 ) JUSTIN CUNNINGHAM, et al., ) ) Defendants. ) MEMORANDUM OPINION AND ORDER Corey Harris, who is currently in the custody of the Northwest Correctional Complex in Tiptonville, Tennessee, filed a pro se Complaint alleging violations of his civil rights. (Doc. No. 1). He has also filed an Application to Proceed in District Court Without Prepaying Fees or Costs (“IFP Application”). The Complaint is now before the Court for initial review pursuant to the Prison Litigation Reform Act (“PLRA”), 28 U.S.C. §§ 1915(e)(2), 1915A. As explained below, the Complaint will be dismissed for failure to state a claim. I. FILING FEE Harris has filed an Amended Application for Leave to Proceed In Forma Pauperis (“IFP Application”) (Doc. No. 6). Under the PLRA, 28 U.S.C. § 1915(a), a prisoner bringing a civil action may be permitted to file suit without prepaying the filing fee required by 28 U.S.C. §1914(a). From a review of Harris’s Amended IFP Application and supporting documentation, it appears that he lacks sufficient financial resources from which to pay the full filing fee in advance. Therefore, the Amended IFP Application (Doc. No. 6) will be granted. Under § 1915(b), Harris nonetheless remains responsible for paying the full filing fee. The obligation to pay the fee accrues at the time the case is filed, but the PLRA provides prisoner- plaintiffs the opportunity to make a “down payment” of a partial filing fee and to pay the remainder in installments. Accordingly, Harris is hereby assessed the full civil filing fee of $350, to be paid as follows: (1) The custodian of Plaintiff’s inmate trust fund account at the institution where he now

resides is DIRECTED to submit to the Clerk of Court, as an initial payment, “20 percent of the greater of – (a) the average monthly deposits to Plaintiff’s account; or (b) the average monthly balance in Plaintiff’s account for the 6-month period immediately preceding the filing of the complaint.” 28 U.S.C. § 1915(b)(1). (2) After the initial filing fee is fully paid, the trust fund officer must withdraw from Plaintiff’s account and pay to the Clerk of this Court monthly payments equal to 20% of all deposits credited to Plaintiff’s account during the preceding month, but only when the amount in the account exceeds $10. Such payments must continue until the entire filing fee is paid in full. 28 U.S.C. § 1915(b)(2). (3) Each time the trust account officer makes a payment to this court as required by this

Order, he or she must print a copy of the prisoner’s account statement showing all activity in the account since the last payment made in accordance with this Order and submit it to the Clerk along with the payment. All submissions to the Court must clearly identify Plaintiff’s name and the case number as indicated on the first page of this Order, and must be mailed to: Clerk, United States District Court, Middle District of Tennessee, 719 Church Street, Nashville, TN 37203. The Clerk of Court is DIRECTED send a copy of this Order to the administrator of inmate trust fund accounts at the Northwest Correctional Complex to ensure that the custodian of Plaintiff’s inmate trust account complies with that portion of 28 U.S.C. § 1915 pertaining to the payment of the filing fee. If is transferred from his present place of confinement, the custodian of his inmate trust fund account MUST ensure that a copy of this Order follows Plaintiff to his new place of confinement for continued compliance. II. PLRA SCREENING STANDARD Under 28 U.S.C. § 1915(e)(2)(B), the court must dismiss any portion of a civil complaint

filed in forma pauperis that fails to state a claim upon which relief can be granted, is frivolous, or seeks monetary relief from a defendant who is immune from such relief. Section 1915A similarly requires initial review of any “complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity,” id. § 1915A(a), and summary dismissal of the complaint on the same grounds as those articulated in Section 1915(e)(2)(B). Id. § 1915A(b). The court must construe a pro se complaint liberally, United States v. Smotherman, 838 F.3d 736, 739 (6th Cir. 2016) (citing Erickson v. Pardus, 551 U.S. 89, 94 (2007)), and accept a plaintiff’s factual allegations as true unless they are entirely without credibility. See Thomas v. Eby, 481 F.3d 434, 437 (6th Cir. 2007) (citing Denton v. Hernandez, 504 U.S. 25, 33 (1992)).

Although pro se pleadings are to be held to a less stringent standard than formal pleadings drafted by lawyers, Haines v. Kerner, 404 U.S. 519, 520–21 (1972); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991), the courts’ “duty to be ‘less stringent’ with pro se complaints does not require us to conjure up [unpleaded] allegations.” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979) (citation omitted). III. FACTUAL ALLEGATIONS AND CLAIMS Harris names two Defendants: Officer Justin Cunningham and the Sparta Police Department. (Doc. No. 1 at 2). Harris alleges that on December 16, 2021, Officer Cunningham conducted a traffic stop for an obscured license plate. (Id. at 4). Harris was a passenger in the vehicle. (Id.). During the stop, Officer Cunningham asked for consent to search the vehicle. (Doc. No. 1-1 at 3). The driver, Angie Taylor, agreed to the search. (Id.). The search revealed methamphetamine, and Harris was charged

with possession of a controlled substance. (Doc. No. 1 at 6). Harris claims that Officer Cunningham unlawfully seized him and searched Taylor’s vehicle in violation of the Fourth Amendment. (Id. at 3). He seeks damages and dismissal of the criminal charges against him. (Id. at 6). IV. ANALYSIS The Complaint is subject to dismissal for two reasons.1 First, Harris does not have standing to challenge the lawfulness of Officer Cunningham’s search of Taylor’s vehicle. Second, Harris has not alleged facts from which the Court may reasonably infer that any aspect of the search or seizure was unreasonable in violation of the Fourth Amendment. A. Standing

The Fourth Amendment protects individuals from “unreasonable searches and seizures.” A vehicle’s passenger, without more, does not have the property or possessory interest in a vehicle required for standing to challenge a search of that vehicle. Rakas v. Illinois, 439 U.S. 128, 148−49 (1978).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Rakas v. Illinois
439 U.S. 128 (Supreme Court, 1979)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Anthony F. McDonald v. Frank A. Hall
610 F.2d 16 (First Circuit, 1979)
James M. Jourdan, Jr. v. John Jabe and L. Boyd
951 F.2d 108 (Sixth Circuit, 1991)
United States v. Terry Lamont Herbin
343 F.3d 807 (Sixth Circuit, 2003)
Jerald Thomas v. Unknown Eby
481 F.3d 434 (Sixth Circuit, 2007)
United States v. Michael Collins
683 F.3d 697 (Sixth Circuit, 2012)
United States v. Sontay Smotherman
838 F.3d 736 (Sixth Circuit, 2016)

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Harris v. Cunningham, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-cunningham-tnmd-2025.