Henry J. Dukes, a/ka/ Henry Jermaine Dukes v. Lt. Coulter, Lt. Franklin, Major A. Spikes, Warden Shane Jackson

CourtDistrict Court, D. South Carolina
DecidedDecember 23, 2025
Docket4:25-cv-12718
StatusUnknown

This text of Henry J. Dukes, a/ka/ Henry Jermaine Dukes v. Lt. Coulter, Lt. Franklin, Major A. Spikes, Warden Shane Jackson (Henry J. Dukes, a/ka/ Henry Jermaine Dukes v. Lt. Coulter, Lt. Franklin, Major A. Spikes, Warden Shane Jackson) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry J. Dukes, a/ka/ Henry Jermaine Dukes v. Lt. Coulter, Lt. Franklin, Major A. Spikes, Warden Shane Jackson, (D.S.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION

Henry J. Dukes, a/ka/ Henry Jermaine ) Dukes, ) ) Plaintiff, ) ) Civil Action No. 4:25-cv-12718-TMC v. ) ) ORDER Lt. Coulter, Lt. Franklin, Major A. Spikes, ) Warden Shane Jackson, ) ) Defendants. ) ) Plaintiff Henry J. Dukes, a state prisoner and frequent pro se litigant in the District of South Carolina, filed this action pursuant to 42 U.S.C. § 1983 alleging the Defendants violated his rights under the Eighth Amendment to the United States Constitution. (ECF No. 1). In accordance with 28 U.S.C. § 636(b)(1) and Local Civil Rule 73.02(B)(2)(d) (D.S.C.), this matter was referred to a magistrate judge for all pretrial proceedings. On September 26, 2025, Plaintiff filed a motion for leave to proceed in forma pauperis. (ECF No. 2). Now before the court is the magistrate judge’s Report and Recommendation (“Report”), recommending that the court deny Plaintiff’s motion to proceed in forma pauperis. (ECF No. 8). The magistrate judge found that Plaintiff is a frequent litigant and, over the years, has accrued at least “three strikes” under 28 U.S.C. § 1915(g) and, as a result, concluded that Plaintiff is precluded from bringing a civil action without prepayment of fees. (ECF No. 8 at 4–5). Specifically, the magistrate judge identified the following prior actions brought by Plaintiff as having been dismissed on grounds enumerated in § 1915(g): Dukes v. Addison, No. 09-cv-00576-HFF; Dukes v. Municipality of Conway, No. 4:09-cv-00690-HFF; Dukes v. J. Reuben Long Detention Center, No. 4:11-cv-00539-HFF. (ECF No. 8 at 3–4). Additionally, the magistrate judge concluded that Plaintiff’s allegations do not fit within the imminent danger exception to § 1915(g) because Plaintiff’s action is based on events alleged to have occurred and ended in August 2024. Id. at 5. Therefore, the magistrate judge recommended that Plaintiff’s motion for in forma pauperis status be denied and that, should the Court adopt the

Report, Plaintiff be given 14 days from the date the Court enters its order adopting the Report and denying in forma pauperis status to pay the full filing fee before this action is dismissed. Id. at 5– 6. Plaintiff filed objections to the Report, (ECF No. 13), arguing that the imminent danger exception to the three-strike rule applies in this case.1 A hearing is unnecessary for the Court to issue a ruling in this matter. The recommendations set forth in the Report have no presumptive weight, and this court remains responsible for making a final determination in this matter. Elijah v. Dunbar, 66 F.4th 454, 459 (4th Cir. 2023) (citing Mathews v. Weber, 423 U.S. 261, 270–71 (1976)). The court is charged with making a de novo determination of those portions of the Report to which a specific

objection is made, and the court may accept, reject, modify, in whole or in part, the recommendation of the magistrate judge or recommit the matter with instructions. 28 U.S.C. § 636(b)(1). Thus, “[t]o trigger de novo review, an objecting party ‘must object to the finding or recommendation on that issue with sufficient specificity so as reasonably to alert the district court of the true ground for the objection.’” Elijah, 66 F.4th at 460 (quoting United States v. Midgette,

1 In addition to submitting his actual objections to the Report, Plaintiff submitted a motion for an extension of time to file objections. (ECF No. 14). Plaintiff does not explain why all of his objections could not have been included with his timely-filed objections, (ECF No. 13), nor does anything in his objections or his motion reflect an intent to raise any grounds other than the imminent danger exception. Accordingly, the Court DENIES Plaintiff’s motion for an extension. (ECF No. 14). 478 F.3d 616, 622 (4th Cir. 2007)). However, the court need only review for clear error “those portions which are not objected to—including those portions to which only ‘general and conclusory’ objections have been made[.]” Dunlap v. TM Trucking of the Carolinas, LLC, 288 F. Supp. 3d 654, 662 (D.S.C. 2017); see also Elijah, 66 F.4th at 460 (noting that “[i]f a litigant objects

only generally, the district court reviews the magistrate’s recommendation for clear error only”). Furthermore, in the absence of specific objections to the Report, the court is not required to give any explanation for adopting the magistrate judge’s recommendation. Greenspan v. Brothers Prop. Corp., 103 F. Supp. 3d 734, 737 (D.S.C. 2015) (citing Camby v. Davis, 718 F.2d 198, 199– 200 (4th Cir. 1983)). Additionally, since Plaintiff is proceeding pro se, this court is charged with construing his pleadings and filings liberally in order to allow for the development of a potentially meritorious case. See Erickson v. Pardus, 551 U.S. 89, 94 (2007); Martin v. Duffy, 858 F.3d 239, 245 (4th Cir. 2017) (noting that “when confronted with the objection of a pro se litigant, [the court] must also be mindful of [its] responsibility to construe pro se filings liberally”). Accordingly, “when

reviewing pro se objections to a magistrate’s recommendation, district courts must review de novo any articulated grounds to which the litigant appears to take issue.” Elijah, 66 F.4th at 460–61. This does not mean, however, that the court can ignore a pro se party’s failure to allege or prove facts that establish a claim currently cognizable in a federal district court. See Stratton v. Mecklenburg Cty. Dep’t of Soc. Servs., 521 Fed. App’x 278, 290 (4th Cir. 2013) (noting that “‘district judges are not mind readers,’ and the principle of liberal construction does not require them to ‘conjure up questions never presented to them or to construct full-blown claims from sentence fragments’” (quoting Beaudett v. City of Hampton, 775 F.2d 1274, 1277–78 (4th Cir. 1985))). As noted, Plaintiff filed objections to the Report. (ECF No. 13). In his objections, Plaintiff does not dispute that he has accrued “three strikes” within the meaning of § 1915(g). And the Court, having conducted a backward-looking inquiry as directed by Pitts v. South Carolina, 65 F.4th 141, 145–46 (4th Cir. 2023), is satisfied that Plaintiff has had at least three prior actions

dismissed on grounds enumerated in § 1915(g). See, e.g., Dukes v. Addison, No. 09-cv-00576- HFF at ECF No. 11 (D.S.C. Apr. 27, 2009) (adopting and incorporating Report (ECF No. 9) which recommended summary dismissal for failure to state a claim); Dukes v. Municipality of Conway, No. 4:09-cv-00690-HFF at ECF No. 18 (D.S.C. May 21, 2009) (summarily dismissing § 1983 action for failure to state a claim upon which relief can be granted as well as other grounds); Dukes v. J. Reuben Long Detention Center, No. 4:11-cv-00539-HFF.

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Related

Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
David E. Camby v. Larry Davis James M. Lester
718 F.2d 198 (Fourth Circuit, 1983)
United States v. Nicholas Omar Midgette
478 F.3d 616 (Fourth Circuit, 2007)
Anthony Martin v. Susan Duffy
858 F.3d 239 (Fourth Circuit, 2017)
Greenspan v. Brothers Property Corp.
103 F. Supp. 3d 734 (D. South Carolina, 2015)
Dunlap v. TM Trucking of the Carolinas, LLC
288 F. Supp. 3d 654 (D. South Carolina, 2017)
Marc Hall v. United States
44 F.4th 218 (Fourth Circuit, 2022)
Larone Elijah v. Richard Dunbar
66 F.4th 454 (Fourth Circuit, 2023)

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Bluebook (online)
Henry J. Dukes, a/ka/ Henry Jermaine Dukes v. Lt. Coulter, Lt. Franklin, Major A. Spikes, Warden Shane Jackson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-j-dukes-aka-henry-jermaine-dukes-v-lt-coulter-lt-franklin-scd-2025.