Jay Folse v. John McCuskey Jr, G. Russell Rollyson, Jr., Wallace Looney, Lisa Hopkins, Stephen Connolly, Michael Nusbaum, Kevin Foreman

CourtDistrict Court, S.D. West Virginia
DecidedOctober 22, 2025
Docket2:22-cv-00171
StatusUnknown

This text of Jay Folse v. John McCuskey Jr, G. Russell Rollyson, Jr., Wallace Looney, Lisa Hopkins, Stephen Connolly, Michael Nusbaum, Kevin Foreman (Jay Folse v. John McCuskey Jr, G. Russell Rollyson, Jr., Wallace Looney, Lisa Hopkins, Stephen Connolly, Michael Nusbaum, Kevin Foreman) is published on Counsel Stack Legal Research, covering District Court, S.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jay Folse v. John McCuskey Jr, G. Russell Rollyson, Jr., Wallace Looney, Lisa Hopkins, Stephen Connolly, Michael Nusbaum, Kevin Foreman, (S.D.W. Va. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF WEST VIRGINIA AT CHARLESTON

JAY FOLSE,

Plaintiff,

v. Civil Action No. 2:22-cv-00171

JOHN MCCUSKEY JR, in his individual and official capacities, G. RUSSELL ROLLYSON, JR., in his individual and official capacities, WALLACE LOONEY, in his individual and official capacities, LISA HOPKINS, in her individual and official capacities, STEPHEN CONNOLLY, in his individual and official capacities, MICHAEL NUSBAUM, in his individual and official capacities, and KEVIN FOREMAN, in his individual and official capacities,

Defendants.

MEMORANDUM OPINION AND ORDER

Pending is Magistrate Judge Tinsley’s Proposed Findings and Recommendation (“PF&R”) (ECF No. 115), filed on May 14, 2025, and plaintiff Jay Folse’s objections thereto (ECF No. 119), filed on June 2, 2025, relating to the following: plaintiff’s pro se “Motion for Discovery Sanctions Against Defendants Rollyson and McCuskey” (ECF No. 107), filed on April 18, 2025; “Motion for Summary Judgment” (ECF No. 86), filed by defendants Kevin Foreman and Wallace Looney on May 24, 2025; and “Defendants’ Motion for Summary Judgment” (ECF No. 88), filed by defendants John B. McCuskey, Jr., G. Russell Rollyson, Jr., Lisa Hopkins, Stephen Connolly, and Michael Nusbaum on May 24, 2025.

I. BACKGROUND Plaintiff filed a pro se complaint (ECF No. 1) on April 8, 2022, followed by an amended complaint (ECF No. 32) on May 31, 2022. He remains pro se. Plaintiff in the operative amended complaint alleges “deprivation of his constitutional rights under the First, Fourth, and Fourteenth Amendments to the

United States Constitution and state law claims for intentional infliction of emotional distress and economic damages.” ECF No. 32 at 1. He brings this Section 1983 action for false arrest, malicious prosecution, and retaliatory arrest and prosecution. Id. Defendants McCuskey, Rollyson, Hopkins, Connolly, and Nusbaum, by counsel, filed an answer to the amended complaint

(ECF No. 62) on September 20, 2023. Defendants Foreman and Looney, by separate counsel, filed an answer (ECF No. 63) to the amended complaint on September 21, 2023. At all relevant times, defendant McCuskey was the Auditor for the State of West Virginia; defendant Rollyson was the Deputy Commissioner of Delinquent and Non-entered Lands (an agent of the West Virginia State Auditor); defendant Looney was a sergeant with the West Virginia Capitol Police; defendant Hopkins was the Senior Deputy Commissioner of Securities and General Counsel for the West Virginia State Auditor’s Office (“WVSAO”); defendant Connolly was Deputy State Auditor and

General Counsel for the WVSAO; defendant Nusbaum was Associate General Counsel and Senior Regulatory Counsel for the WVSAO; and defendant Foreman was the Director of the West Virginia Capitol Police. See ECF No. 8 at 2. A.

Plaintiff’s allegations stem from interactions between plaintiff and defendants in connection with plaintiff’s purchase of tax liens from the WVSAO. See ECF No. 32 at ¶¶5-12, 16-42. After a years-long breakdown of relationship between plaintiff and the WVSAO, on August 12, 2021, defendant Rollyson filed a petition with the Magistrate Court of Kanawha County, West Virginia, for the issuance of a Personal Safety Order (“PSO”) against plaintiff, wherein Rollyson stated that the PSO was necessary because plaintiff made “repeated credible threats of bodily injury knowing or having reason to know that the threats caused reasonable fear for safety in violation of West Virginia

Code § 53-8-4(a)(3).” ECF No. 22-3 at 2. The Kanawha County Magistrate Court, acting by Magistrate Shelton, issued the PSO on August 20, 2021. See ECF No. 22-3 at 3. The PSO, endorsed by Magistrate Shelton on August 20, 2021, expired after one year on August 20, 2022. Id. The PSO prescribed the following two pertinent restrictions, the

first relating to the Auditor’s Office and its General Counsel, and the second related specifically to the petitioner Rollyson: (1) Respondent [Folse] shall not have verbal contact with the WVSAO or the General Counsel. All communication shall be via email or USPS.

(2) Respondent [Folse] shall refrain from contacting, attempting to contact, or harassing the person(s) named above [Rollyson], directly or indirectly, or through third party, regardless of whether those third parties know of this Order.

Id. at 2. Plaintiff appealed the PSO to the Kanawha County Circuit Court which affirmed the PSO after plaintiff failed to appear for a scheduled hearing. See ECF No. 56-1 at 3. He appealed to the Supreme Court of Appeals of West Virginia, which affirmed the circuit court order. J.F. v. G.R., No. 21-0813, 2022 WL 17592199, at *1 (W. Va. Dec. 13, 2022). The Supreme Court found that the PSO “prohibit[ed] petitioner [Folse] from contacting, attempting to contact, or harassing respondent [Rollyson] either directly or indirectly through other state employees,” and “forbade petitioner from having verbal contact with various offices associated with respondent's official position, limiting petitioner's communication with those offices to e-mail and the United States Postal Service.” Id. Since the PSO was already then expired, the court denied plaintiff’s appeal as moot. Id. at 2.

Plaintiff alleges in the operative complaint that “[d]efendants collectively conspired to file for a [PSO] for the improper purpose to exclude the [p]laintiff from tax sales, to bar him from obtaining tax deeds to properties he already purchased, and to put him in a catch 22 situation where he would be forced to either violate [the PSO] or lose his investment of

hundreds of thousands of dollars.” ECF No. 32 at ¶ 43. It is clear from the language of the order, as quoted above, that the PSO did none of those things. Plaintiff alleges various counts under 42 U.S.C. § 1983. See id. As to defendant Looney, plaintiff alleges that Looney “filled out and signed a criminal complaint for the charge of violating [the PSO].” Id. at ¶ 50. The criminal complaint, filed with Magistrate Hall on October 19, 2021,

states the grounds for the assertion that Folse had violated the terms of the PSO as follows: Defendant [Folse] filed a lawsuit against Deputy Auditor Rollyson and Auditor McCuskey. Defendant attempted to notice a multi-day deposition of both individuals. On October 18, 2021, the Circuit Court of Ohio County issued an Order quashing the deposition notice as Defendant’s “ . . . attempt to take these depositions was undertaken for an improper purpose.” Later that day, Defendant began posting comments on State Auditor J.B. McCuskey’s personal Facebook page. Said comments were numerous and clearly done with the intent to abuse, harass and violate the terms of the Final Personal Safety Order entered by Magistrate Shelton. Further, Defendant has emailed Deputy Auditor Rollyson on several occasions since the issuance of the Final PSO in what can be characterized as an unprofessional and harassing manner.

ECF No. 51-3 at 3. Based on this submission, Kanawha Magistrate Brent Hall found probable cause for plaintiff’s arrest for violation of the PSO and issued an arrest warrant. ECF No. 32 at ¶ 51. Plaintiff was arrested at a tax auction sale in Marion County, and “was held in North Central Regional Jail.” Id. at ¶ 54-56. Ultimately, the charges against plaintiff were voluntarily dismissed by the Kanawha County prosecutor. Id. at ¶ 111. Plaintiff maintains that there was a lack of probable cause for the issuance of a warrant, contending the criminal complaint’s assertions that he “filed a lawsuit,” “attempted to notice a multi-day deposition,” and “posted comments on State Auditor J.B. McCuskey’s personal Facebook page” were not violations. ECF No. 119 at 14.

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Jay Folse v. John McCuskey Jr, G. Russell Rollyson, Jr., Wallace Looney, Lisa Hopkins, Stephen Connolly, Michael Nusbaum, Kevin Foreman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jay-folse-v-john-mccuskey-jr-g-russell-rollyson-jr-wallace-looney-wvsd-2025.