Jane Doe v. City of Detroit, et al.

CourtDistrict Court, E.D. Michigan
DecidedDecember 18, 2025
Docket2:25-cv-12689
StatusUnknown

This text of Jane Doe v. City of Detroit, et al. (Jane Doe v. City of Detroit, 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
Jane Doe v. City of Detroit, et al., (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Jane Doe, Case No. 25-12689 Plaintiff, Hon. Jonathan J.C. Grey v.

City of Detroit, et al.,

Defendants. ____________________________________/

OPINION AND ORDER GRANTING PLAINTIFF’S APPLICATION TO PROCEED WITHOUT PREPAYING FEES OR COSTS (ECF No. 2), PARTIALLY DISMISSING COMPLAINT, AND DENYING MOTION TO PROCEED ANONYMOUSLY (ECF No. 4)

I. BACKGROUND On August 26, 2025, pro se Plaintiff Jane Doe, as personal representative of the Estate of Tyrone Burch Jr. (“Burch”), filed this case along with an application to proceed without prepaying fees or costs and a motion to proceed anonymously. (ECF Nos. 1, 2, 4, respectively.) On October 14, 2025, Doe filed a “motion for leave to file [an] amended complaint,” which consists of an “evidentiary guide” and numerous exhibits. (ECF No. 7.) On October 24, 2025, Doe filed a motion to supplement the record, which consists of more exhibits. (ECF No. 8.) The Court treats these two motions (ECF Nos. 7, 8) as attachments to the

original complaint (ECF No. 1). In the complaint, Doe alleges that Defendant Paul Duane Jones violated Burch’s Fourth Amendment rights. Doe also brings a Monell

claim against the City of Detroit. (ECF No. 1.) For the following reasons, the Court GRANTS Doe’s application to proceed without prepaying fees or costs, PARTIALLY DISMISSES the

complaint for failure to state a claim on which relief may be granted, and DENIES her motion to proceed anonymously. II. BACKGROUND

According to the complaint, on March 19, 2011, Jones fatally shot Burch outside of Palms Night Club, located at 15350 Fenkell, Detroit, Michigan. (ECF No. 1, PageID.13.) Jones was the owner of Palms Night

Club. (Id., PageID.62.) Doe also alleges that the subsequent investigation conducted by the Detroit Police Department (“DPD”) was faulty and violated numerous DPD directives. (ECF No. 7–1.)

III. LEGAL STANDARDS Under 28 U.S.C. § 1915, the Court may allow a person to proceed without prepayment of fees or costs, i.e., in forma pauperis. However, the Court is required to review each case for summary dismissal if the action

is frivolous, malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2).

To determine whether this matter states a claim on which relief may be granted, the Court applies the Federal Rule of Civil Procedure 12(b)(6) standard. Therefore, the Court must assess whether the

complaint alleges facts sufficient to “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 547, 570 (2007)). When assessing a complaint under Rule 12(b)(6), the Court must

give the plaintiff the benefit of the doubt and must accept all the complaint’s factual allegations as true. Keys v. Humana, Inc., 684 F.3d 605, 608 (6th Cir. 2012).

Nevertheless, the Court will not presume the truth of any legal conclusions stated in the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). If the pleaded facts do not raise a right to relief, the Court must

dismiss the complaint. Winnett v. Caterpillar, Inc., 553 F.3d 1000, 1005 (6th Cir. 2009). Courts generally rely only on the facts or claims stated in the complaint. Rondigo, L.L.C. v. Township of Richmond, 641 F.3d 673, 680 (6th Cir. 2011) (citations omitted). However, the Court may consider

items appearing in the record of the case without converting the motion into one for summary judgment so long as the items are referenced in the complaint and are central to the claims. Id.

IV. ANALYSIS A. Application to Proceed in Forma Pauperis

In reviewing Doe’s application to proceed in forma pauperis, the Court finds that Doe is unable to prepay the filing fee. (ECF No. 2.) Thus, the Court GRANTS her application to proceed in forma pauperis under 28 U.S.C. § 1915.

B. Dismissal of Jones

1. Fourth Amendment Claim Doe brings a § 1983 Fourth Amendment claim against Jones alleging he used “unreasonable deadly force” when he shot Burch. (ECF No. 1, PageID.9.) To state a cause of action under § 1983, a plaintiff must allege two

elements: (1) that the defendant acted under color of state law and (2) that the defendant deprived the plaintiff of a federally protected right. Gomez v. Toledo, 446 U.S. 635, 640 (1980). “A plaintiff may not proceed under § 1983 against a private party ‘no matter how discriminatory or wrongful’

the party's conduct.” Tahfs v. Proctor, 316 F.3d 584, 590 (6th Cir. 2003) (quoting Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 50 (1999)). “As a matter of substantive constitutional law, the state-action requirement

reflects judicial recognition of the fact that ‘most rights secured by the Constitution are protected only against infringement by governments.’” Lugar v. Edmondson Oil Co., 457 U.S. 922, 936 (1982) (quoting Flagg

Bros., Inc. v. Brooks, 436 U.S. 149, 156 (1978)). Only when a private actor’s conduct is “fairly attributable to the state” can be he be acting under color of state law. Lugar, 457 U.S. at 937.

The Sixth Circuit recognizes three tests for determining whether private conduct is fairly attributable to the state: the public function test, the state compulsion test, and the nexus test. Ellison v. Garbarino, 48

F.3d 192, 195 (6th Cir. 1995). The public function test requires that the private entity exercise powers which are traditionally exclusively reserved to the state. … The state compulsion test requires proof that the state significantly encouraged or somehow coerced the private party, either overtly or covertly, to take a particular action so that the choice is really that of the state. Finally, the nexus test requires a sufficiently close relationship (i.e., through state regulation or contract) between the state and the private actor so that the action taken may be attributed to the state. Id. at 195.

Here, Doe fails to allege facts supporting any plausible inference that Jones acted under color of state law when he shot Burch. Because Doe’s suit against Jones fails the first element required for a § 1983

action, the Court DISMISSES her Fourth Amendment claim. 2. Wrongful Death Claim Doe also brings a wrongful death claim against Jones pursuant to

MCL § 600.2922. (ECF No. 1, PageID.10 (Section 600.2922 “applies because Defendant Jones’ unjustified discharge of a firearm caused Mr. Burch’s death.”).)

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