Havens v. Aransas County Sheriff's Department

CourtDistrict Court, S.D. Texas
DecidedAugust 8, 2025
Docket2:24-cv-00243
StatusUnknown

This text of Havens v. Aransas County Sheriff's Department (Havens v. Aransas County Sheriff's Department) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Havens v. Aransas County Sheriff's Department, (S.D. Tex. 2025).

Opinion

Southern District of Texas ENTERED August 08, 2025 UNITED STATES DISTRICT COURT athan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION CHRISTOPHER DALE HAVENS, § § Plaintiff, § V. § CIVIL ACTION NO. 2:24-CV-00243 § ARANSAS COUNTY SHERIFF’S § DEPARTMENT, et ail., § § Defendants. ORDER ADOPTING MEMORANDUM AND RECOMMENDATION Before the Court is Magistrate Judge Jason B. Libby’s Memorandum and Recommendation (“M&R”). (D.E. 17). The M&R recommends that the Court dismiss Plaintiff's complaint with prejudice, count the dismissal as a “strike” for purposes of 28 U.S.C.§ 1915(g), and instruct the Clerk of Court to send notice of this dismissal to the Manager of the Three Strikes List for the Southern District of Texas. /d. at 4. Plaintiff filed written objections to the M&R. (D.E. 24).' I. Law When a party objects to the findings and recommendations of a magistrate judge, the district judge “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C.§ 636(b)(1)(C). As to any portion for which no objection is filed, a district court reviews for clearly erroneous factual findings and conclusions of law. United States v. Wilson, 864 F.2d 1219, 1221 (Sth Cir. 1989) (per

' The Court mailed the M&R to Plaintiff twice. On January 31, 2024, the M&R was delivered to Plaintiff at Garza West Unit. (D.E. 20). On February 25, 2025, the M&R was delivered to Plaintiff at Aransas County Detention Center. (D.E. 23). To ensure that Plaintiff received the M&R and, thus, had an opportunity to object, the Court uses the second date of delivery, February 25, 2025, to calculate Plaintiff's objection deadline. Accordingly, Plaintiff's objections were due by March 11, 2025. See Fed. R. Civ. P. 72(b); 28 U.S.C. § 636(b)(1); General Order No. 2002-13. Plaintiff's objections, which were filed with the Court on March 5, 2025, (D.E. 24), were timely. 1/6

curiam). II. Analysis A.M&R The M&R describes the reason for recommending dismissal as follows. Plaintiffs complaint is “confusing,” “disorganized,” and “not dissimilar to many of the lawsuits [Plaintiff] has recently filed in this Court.” (D.E. 17, p. 1). The Court held a telephonic hearing on December 23, 2024, in which the Court “advised Plaintiff his complaint was subject to dismissal because his pleading was confusing and he has failed to state plausible claims.” /d. at 2. The Court further advised Plaintiff that he could either (a) dismiss his case without prejudice if he did not want to pay the filing fee or incur strikes or (b) file an amended complaint within 30 days to cure the pleading deficiencies. /d. Plaintiff stated he understood and had no questions. /d. Following the telephonic conference, the Court entered a written order for Plaintiff to file an amended complaint on or before January 23, 2025. (D.E. 13, p. 3). This order detailed the deficiencies in Plaintiff's complaint, id. at 1-2, and provided detailed directions for amending the complaint, id. at 3-4. The order concluded, “If Plaintiff fails to either file an amended complaint or, alternatively, fails to file a motion to voluntarily dismiss this action, this case will be summarily dismissed.” Jd. at 4. The order reiterated this and other warnings regarding the possibility of dismissal. /d. at 5. Plaintiff did not file an amended complaint. So, reasoning that “Plaintiff has alleged confusing and conclusory allegations which fail to state a plausible claim,” the M&R recommends dismissal with prejudice. (D.E. 17, p. 3-4). B. Objections Liberally construed, Plaintiff objects that: (1) the M&R screens Plaintiff's complaint in a

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cursory fashion; (2) the Court has demonstrated bias against Plaintiff; (3) the Court did not order a more definite statement or responses to a questionnaire before recommending dismissal; (4) the Court’s order for Plaintiff to remove dialogue from his complaint is inconsistent with the Court’s reasoning that his complaint contains conclusory allegations; (5) the Court must construe Plaintiff's pleadings liberally because he is pro se; (6) Plaintiff has been prejudiced in meeting the Court’s deadlines by his transfer to Garza West Unit and related issues with access to legal materials, writing materials, and mail. See (D.E. 24, p. 1-2). Plaintiff also recommends that the Court remove Magistrate Judge Libby from this case. /d. at 2. First, the Court addresses Plaintiff's complaints of bias in the screening process. Then, the Court addresses Plaintiff's issues with access to legal materials, writing materials, and mail. Last, the Court addresses Plaintiff's failure to state a claim upon which relief can be granted. i. Bias Objections The Court takes seriously its duty to treat all parties fairly and without bias. The Court also remains “mindful of its duty to treat pro se litigants with more leniency than represented parties.” Welsh v. Collier, 2020 U.S. Dist. LEXIS 199154, at *6 (W.D. Tex. October 27, 2020) (Pitman, J.). That said, the Court has provided Plaintiff ample opportunity to plead his best case. At the December 2024 telephonic conference, the Court explained to Plaintiff that his “pleadings are confusing and it’s basically impossible ...to understand what [Plaintiff is] complaining about.” (D.E. 15, p. 11). However, the Court recognized that Plaintiff has a right to amend his complaint to state his claims clearly. Jd. at 12. The Court clarified that Plaintiffs amended complaint should eliminate long narratives and quotations from conversations and instead provide “a short statement of who [Plaintiff is] suing and why.” /d. at 12-13. When asked if he understood, Plaintiff indicated, “[T]hat better explains things.” Jd. at 13. The written order

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that followed detailed the deficiencies in Plaintiff's complaint, (D.E. 13, p. 2); provided directions for amending the complaint, id. at 3; and described what would happen if Plaintiff did not file an amended complaint, id. at 4. Far from providing a cursory screening process, the Court—through the telephonic conference and detailed order that followed—gave Plaintiff a full and fair opportunity to amend his complaint and plead claims upon which relief can be granted. Though Plaintiff is correct that the Court did not order Plaintiff to submit a response to questionnaire or a more definite statement, this is because the Court ordered Plaintiff to articulate his claims through an amended complaint. Id. Finally, the process the Court followed is consistent with construing Plaintiff's pro se pleadings liberally. See Burgess v. United States, 2021 U.S. Dist. LEXIS 183827, at *6 (N.D. Tex. September 27, 2021) (Pittman, J.) (‘Pro se filings are liberally construed, but those relaxed standards do not require the Court to guess or to develop the arguments on the litigant’s behalf.” (citing United States v. Pineda, 988 F.2d 22, 23 (Sth Cir. 1993))). Accordingly, although Plaintiff may feel that the Court is biased against him, the record reflects that the Court has treated Plaintiff with fairness and the leniency that is appropriate for pro se litigants.

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Havens v. Aransas County Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/havens-v-aransas-county-sheriffs-department-txsd-2025.