Jacob Hawkins-Bivins v. 68th District Court, et al.

CourtDistrict Court, E.D. Michigan
DecidedFebruary 19, 2026
Docket2:25-cv-12437
StatusUnknown

This text of Jacob Hawkins-Bivins v. 68th District Court, et al. (Jacob Hawkins-Bivins v. 68th District Court, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacob Hawkins-Bivins v. 68th District Court, et al., (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JACOB HAWKINS-BIVINS,

Plaintiff, Case No. 2:25-cv-12437

v. Hon. Susan K. DeClercq United States District Judge 68TH DISTRICT COURT, et al.,

Defendants. ________________________________/

OPINION AND ORDER GRANTING PLAINTIFF’S APPLICATION TO PROCEED IN FORMA PAUPERIS (ECF No. 2) AND SUMMARILY DISMISSING COMPLAINT (ECF No. 1) In July 2025, pro se Plaintiff Jacob Hawkins-Bivins filed this civil rights action against Defendants 68th District Court and Genesee County in the United States District Court for the Western District of Michigan. ECF No. 1. He also filed an application to proceed in forma pauperis (IFP). ECF No. 2. But because “[t]he events underlying the complaint occurred in Genesee County,” the case was transferred in August 2025 to the Eastern District of Michigan as the proper venue. ECF No. 3 at PageID.9. Hawkins-Bivins’s application to proceed IFP supports his claim of poverty, so it will be granted. However, as explained below, his complaint will be dismissed under 28 U.S.C. § 1915(e)(2) for failure to state a claim upon which relief can be granted. I. BACKGROUND In his five-sentence complaint, Hawkins-Bivins alleges that

[t]he 68th District Court allowed the witnesses on [his] case to lie on [him] under oath. The District Court Judge also allowed it and used all false testimony to bond [him] over to [ ] 7th Circuit Court. The evidence was not based off facts they were based off all lies. ECF No. 1 at PageID.3 (cleaned up). Hawkins-Bivins also states that his brief in support of this petition “has all the underlying facts and proof to support” his claim but he does not attach it. Id. (cleaned up). The relief he seeks is to hold the 68th District Court accountable for their actions and to “put on the record that the testimony of the state witnesses were all false.” Id. at PageID.4 (cleaned up). I. LEGAL STANDARD Because Hawkins-Bivins proceeds in forma pauperis, his claims must be

reviewed under the standards set forth in the Prison Litigation Reform Act of 1996, 28 U.S.C. § 1915(e)(2). These standards require district courts to dismiss any claim that “fails to state a claim on which relief can be granted.” 28 U.S.C. § 1915(e)(2)(B).

See also Flanory v. Bonn, 604 F.3d 249, 252 (6th Cir. 2010); Smith v. Campbell, 250 F.3d 1032, 1036 (6th Cir. 2001). Specifically, the Court must dismiss any claim that “(i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted;

or (iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B). Hawkins-Bivins’s also proceeds pro se, so his pleadings are held to “less stringent standards than formal pleadings drafted by lawyers” and are liberally

construed. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). Even so, Hawkins-Bivins’s pro se status does not exempt him from meeting basic pleading requirements and complying with the Civil Rules.

See Porter v. Genovese, 676 F. App’x 428, 440 (6th Cir. 2017). His complaint must still set forth “a short and plain statement of the claim showing that the pleader is entitled to relief,” FED. R. CIV. P. 8(a)(2), one that would “give the defendant[s] fair notice” of what the claim is and the grounds on which it rests. Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 555 (2007) (citation omitted). Further, his complaint must still “contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010)

(quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)) (holding that the Civil Rule 12(b)(6) standard also applies to dismissals under § 1915(e)(2)(B)(ii)). III. ANALYSIS The issue in this action is whether Hawkins-Bivins can seek relief on a claim

that a state district judge used false testimony to bind plaintiff to a state circuit court. For this screening under § 1915(2)(2), this Court construes Hawkins-Bivins’s pro se action as a 42 U.S.C. § 1983 action because he aims to sue the 68th District Court

and Genesee County in the context of a state criminal proceeding. See Erickson, 551 U.S. at 94. For the reasons explained below, his complaint does not state a claim on which relief may be granted, so it will be dismissed, and the case will be closed.

A. Defendant 68th District Court is not a “Suable Person” under § 1983 To state a claim under § 1983, a plaintiff must allege: “(a) the deprivation of a right secured by the Constitution or federal law; and (b) that the deprivation was

caused by a person acting under color of state law.” Aarti Hosp., LLC v. City of Grove City, Ohio, 350 F. App’x 1, 11 (6th Cir. 2009) (quoting Alkire v. Irving, 330 F.3d 802, 813 (6th Cir. 2003)). A state court, however, is not a “person” subject to suit under § 1983. See Hohenberg v. Shelby Cnty., 68 F.4th 336, 343 (6th Cir. 2023) (citing Foster

v. Walsh, 864 F.2d 416, 418 (6th Cir. 1988) (per curiam)). The 68th District Court is a Michigan state court. See MICH. COMP. LAWS § 600.8134(3). Because a state court is not a “person” capable of being sued within

the meaning of § 1983, Hawkins-Bivins cannot maintain a § 1983 action against the 68th District Court in federal court. His § 1983 claim must therefore be dismissed. Moreover, to the extent Hawkins-Bivins seeks retrospective or otherwise non- prospective relief against the 68th District Court, his claim is independently barred

by Eleventh Amendment immunity. Pucci v. Nineteenth Dist. Court, 628 F.3d 752, 764 (6th Cir. 2010) (holding that Michigan trial-level district courts are generally entitled to the immunity protections of the Eleventh Amendment, and all federal

claims against it must be dismissed). B. Hawkins-Bivins does not State a Plausible Claim against Genesee County Hawkins-Bivins pleads no facts that would support imposing liability on

Defendant Genesee County under any cognizable theory. Although he names Genesee County as a defendant, he does not allege how the County was involved in the events at issue, what actions it purportedly took, or how those actions caused him

harm. See generally ECF No. 1. His pleading efforts against Genesee County are devoid of factual or legal elaboration.

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Related

The Fair v. Kohler Die & Specialty Co.
228 U.S. 22 (Supreme Court, 1913)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Flanory v. Bonn
604 F.3d 249 (Sixth Circuit, 2010)
Pucci v. Nineteenth District Court
628 F.3d 752 (Sixth Circuit, 2010)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Lloyd D. Alkire v. Judge Jane Irving
330 F.3d 802 (Sixth Circuit, 2003)
Aarti Hospitality LLC v. City of Grove City, Ohio
350 F. App'x 1 (Sixth Circuit, 2009)
Elgene Porter v. Kevin Genovese
676 F. App'x 428 (Sixth Circuit, 2017)
Sarah Hohenberg v. Shelby Cnty., Tenn.
68 F.4th 336 (Sixth Circuit, 2023)

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Bluebook (online)
Jacob Hawkins-Bivins v. 68th District Court, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jacob-hawkins-bivins-v-68th-district-court-et-al-mied-2026.