HEATHEN BLODHARN v. STATE OF OHIO, et al.

CourtDistrict Court, N.D. Ohio
DecidedMay 15, 2026
Docket1:26-cv-00184
StatusUnknown

This text of HEATHEN BLODHARN v. STATE OF OHIO, et al. (HEATHEN BLODHARN v. STATE OF OHIO, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HEATHEN BLODHARN v. STATE OF OHIO, et al., (N.D. Ohio 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

HEATHEN BLODHARN, ) Case No. 1:26-cv-184 ) Plaintiff, ) Judge J. Philip Calabrese ) v. ) Magistrate Judge ) Jennifer Dowdell Armstrong STATE OF OHIO, et al., ) ) Defendants. ) )

OPINION AND ORDER Plaintiff Heathen Blodharn, a prisoner currently incarcerated in the Allen Oakwood Correctional Center, filed this in forma pauperis civil rights complaint in under 42 U.S.C. § 1983, without a lawyer, against 22 named Defendants and 10 Jane/John Doe Defendants. (ECF No. 1.) For the reasons that follow, the Court DISMISSES his complaint. BACKGROUND In May 2022, Plaintiff was transferred to Ohio pursuant to the Interstate Corrections Compact from Montana, where he was serving prison sentences for multiple Montana convictions. Since his transfer, he has been housed in various correctional institutions in Ohio, including the Mansfield Correctional Institution and the Trumbull Correctional Institution (, where he was incarcerated when he filed this action on January 23, 2026. In complaint, Plaintiff sues the State of Ohio; Annette Chambers-Smith, Director of the Ohio Department of Rehabilitation and Correction; and Tracy Reveal, the ODRC’s Coordinator for the Interstate Corrections Compact on claims challenging the lawfulness of his transfer to and imprisonment in Ohio pursuant to the compact. (See ECF No. 1, ¶¶ 79–85, PageID #10.) In addition, he sues nearly

twenty employees and officials at the Mansfield and Trumbull Correctional Institutions for a host of alleged civil rights violations relating to his treatment and the conditions of his confinement during his incarceration from 2023 through 2025. Among other things, he alleges retaliation by excessive force and false conduct reports for filing grievances and lawsuits against prison personnel, denial of care for serious medical needs, and denial of his First Amendment right of access to the courts, to

protest his conditions of his confinement by hunger strike, to send and receive mail, to privacy in accordance with the attorney-client privilege, and to practice an unspecified religion. He seeks damages, declaratory relief, and injunctive relief ordering him to be returned to Montana immediately and for the “Defendants to list only [his] legal name (‘Heathen Blodharn’) on his records, Identification card, etc. in Ohio.” (Id., ¶¶ 94–97, PageID #12.)

GOVERNING LEGAL STANDARD Because Plaintiff is proceeding in forma pauperis and sues governmental Defendants, the Court must review his complaint pursuant to 28 U.S.C. §§ 1915(e) and 1915A. See McGore v. Wrigglesworth, 114 F.3d 601, 608 (6th Cir.1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). Those statutes require the Court to dismiss Plaintiff’s complaint, or any portion of it, that the Court determines is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010). Pro se pleadings receive liberal

construction. See Boag v. MacDougall, 454 U.S. 364, 365 (1982); Haines v. Kerner, 404 U.S. 519, 520 (1972). Nonetheless, the lenient treatment generally accorded pro se pleadings “has limits.” Pilgrim v. Littlefield, 92 F.3d 413, 416 (6th Cir. 1996). Pro se plaintiffs must still meet still basic pleading requirements, and courts are not required to conjure allegations or construct claims on their behalf. See Martin v. Overton, 391 F.3d 710, 714 (6th Cir. 2004); Erwin v. Edwards, 22 F. App’x 579, 580

(6th Cir. 2001). ANALYSIS Under this standard, the Court finds that Plaintiff’s complaint warrants sua sponte dismissal in accordance with Sections 1915(e) and 1915A. I. Plaintiff’s primary claims in this case are against the State of Ohio, Annette Chambers-Smith, and Tracy Reveal, challenging the lawfulness of his transfer to and

imprisonment in Ohio. Plaintiff already challenged the lawfulness of his transfer to and imprisonment in Ohio in prior actions filed in the Ohio Supreme Court, the Ohio Court of Claims, and the Montana Supreme Court, and all of which denied him relief. See Blodharn v. Chambers-Smith, 174 Ohio St. 3d 453, 2024-Ohio-645, 237 N.E.3d 159 (denying Plaintiff’s petition for a writ of habeas corpus seeking release from an Ohio prison following his transfer from Montana); Blodharn v. ODRC, No. 2023- 00218 (Ohio Ct. Cl. Aug. 18, 2023) (dismissing Plaintiff’s claims that he was falsely imprisoned in Ohio pursuant to the Interstate Corrections Compact); Blodharn v. State of Montana, No. OP 24-0689, 2024 WL 5075184 (Mont. Dec. 11, 2014) (denying Plaintiff’s petition challenging the lawfulness of his transfer).

In addition, Plaintiff challenged the lawfulness of his transfer and imprisonment in Ohio in a prior civil rights action he filed under Section 1983 in the Southern District of Ohio, where a federal Magistrate Judge recommended dismissal of his claims, reasoning that the claims fail to state a claim for relief and are subject to dismissal on the basis of res judicata. See Warren v. Chambers-Smith, No. 2:24- cv-1565, ECF No. 5-1, at 16–18 (S.D. Ohio Sept. 20, 2024) (Report and

Recommendation). The Court agrees with that reasoning and the conclusions of the Magistrate Judge in the Southern District. Under the doctrine of res judicata, a final judgment on the merits bars any and all claims by the parties or their privies based on the same cause of action as to every matter actually litigated as well as every theory of recovery that could have been presented in a prior case. Parker v. Gibbons, 62 F. App’x 95, 96 (6th Cir. 2003). Res judicata bars a claim where there is: (1) a prior final decision on

the merits by a court of competent jurisdiction; (2) a second action follows, involving the same parties, or their privies; and (3) the second action raises claims that actually were or could have been litigated in the first action; and (4) the second action involves the same subject matter as the previous action. Hapgood v. Warren 127 F.3d 490, 493 (6th Cir. 1997). These elements are all present with respect to Plaintiff’s claims pertaining to his transfer and imprisonment in Ohio. Courts of competent jurisdiction have issued valid final judgments on the merits of claims already asserted by Plaintiff challenging

the lawfulness of his transfer to Ohio pursuant to the ICC, this action involves the same parties or their privies and arise out of the same transaction or occurrence as prior cases, and Plaintiff did (or could have) raised the claims he raises here as to the lawfulness of his transfer in the prior cases. Further, as the Magistrate Judge noted in the Plaintiff’s pending case in the Southern District, federal courts of appeals have held that “alleged violations of the [Interstate Corrections Compact] do not constitute

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Boag v. MacDougall
454 U.S. 364 (Supreme Court, 1982)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Torrance Pilgrim v. John Littlefield
92 F.3d 413 (Sixth Circuit, 1996)
John H. Hapgood v. City of Warren
127 F.3d 490 (Sixth Circuit, 1997)
Eric Martin v. William Overton
391 F.3d 710 (Sixth Circuit, 2004)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Erwin v. Edwards
22 F. App'x 579 (Sixth Circuit, 2001)
Parker v. Gibbons
62 F. App'x 95 (Sixth Circuit, 2003)
Blodharn v. Chambers-Smith
2024 Ohio 645 (Ohio Supreme Court, 2024)

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HEATHEN BLODHARN v. STATE OF OHIO, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/heathen-blodharn-v-state-of-ohio-et-al-ohnd-2026.