Killian v. Jefferson County Jail

CourtDistrict Court, E.D. Missouri
DecidedJanuary 24, 2022
Docket4:21-cv-01294
StatusUnknown

This text of Killian v. Jefferson County Jail (Killian v. Jefferson County Jail) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Killian v. Jefferson County Jail, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JESSE NOAL KILLIAN, ) ) Plaintiff, ) ) v. ) No. 4:21-cv-01294-JMB ) JEFFERSON COUNTY JAIL, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter comes before the Court on the motion of plaintiff Jesse Noal Killian for leave to commence this civil action without prepayment of the required filing fee. (Docket No. 2). Having reviewed the motion and the financial information submitted in support, the Court has determined that plaintiff lacks sufficient funds to pay the entire filing fee, and will assess an initial partial filing fee of $1.00. See 28 U.S.C. § 1915(b)(1). Additionally, for the reasons discussed below, the Court will dismiss plaintiff’s claim against the Jefferson County Jail, as well as the official capacity claim against defendant Unknown Adams. However, the Court will direct the Clerk of Court to issue process on defendant Adams in his individual capacity as to plaintiff’s claim of excessive force. 28 U.S.C. § 1915(b)(1) Pursuant to 28 U.S.C. § 1915(b)(1), a prisoner bringing a civil action in forma pauperis is required to pay the full amount of the filing fee. If the prisoner has insufficient funds in his or her prison account to pay the entire fee, the Court must assess and, when funds exist, collect an initial partial filing fee of 20 percent of the greater of (1) the average monthly deposits in the prisoner’s account, or (2) the average monthly balance in the prisoner’s account for the prior six-month period. After payment of the initial partial filing fee, the prisoner is required to make monthly payments of 20 percent of the preceding month’s income credited to the prisoner’s account. 28 U.S.C. § 1915(b)(2). The agency having custody of the prisoner will forward these monthly payments to the Clerk of Court each time the amount in the prisoner’s account exceeds $10.00, until the filing fee is fully paid. Id.

Plaintiff has not submitted a copy of his inmate account statement as required by 28 U.S.C. § 1915(a)(2), asserting that he has requested his statement multiple times, but has been refused. (Docket No. 5). Despite the lack of an account statement, the Court has reviewed the financial information contained in the motion for leave to proceed in forma pauperis, and will assess an initial partial filing fee of $1.00. See Henderson v. Norris, 129 F.3d 481, 484 (8th Cir. 1997) (explaining that when a prisoner is unable to provide the court with a certified copy of his inmate account statement, the court should assess an amount “that is reasonable, based on whatever information the court has about the prisoner’s finances”). If plaintiff is unable to pay the initial partial filing fee, he must submit a copy of his inmate account statement in support of his claim.

Legal Standard on Initial Review Under 28 U.S.C. § 1915(e)(2), the Court is required to dismiss a complaint filed in forma pauperis if it is frivolous, malicious, or fails to state a claim upon which relief can be granted. To state a claim under 42 U.S.C. § 1983, a plaintiff must demonstrate a plausible claim for relief, which is more than a “mere possibility of misconduct.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw upon judicial experience and common sense. Id. at 679. The court must “accept as true the facts alleged, but not legal conclusions or threadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Barton v. Taber, 820 F.3d 958, 964 (8th Cir. 2016). See also Brown v. Green Tree Servicing LLC, 820 F.3d 371, 372-73 (8th Cir. 2016) (stating that court must accept factual allegations in complaint as true, but is not required to “accept as true any legal conclusion couched as a factual allegation”).

When reviewing a pro se complaint under 28 U.S.C. § 1915(e)(2), the Court must give it the benefit of a liberal construction. Haines v. Kerner, 404 U.S. 519, 520 (1972). A “liberal construction” means that if the essence of an allegation is discernible, the district court should construe the plaintiff’s complaint in a way that permits his or her claim to be considered within the proper legal framework. Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015). However, even pro se complaints are required to allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). See also Stone v. Harry, 364 F.3d 912, 914-15 (8th Cir. 2004) (stating that federal courts are not required to “assume facts that are not alleged, just because an additional factual allegation would have formed a stronger

complaint”). In addition, affording a pro se complaint the benefit of a liberal construction does not mean that procedural rules in ordinary civil litigation must be interpreted so as to excuse mistakes by those who proceed without counsel. See McNeil v. United States, 508 U.S. 106, 113 (1993). The Complaint Plaintiff is a self-represented litigant who is currently incarcerated at the Eastern Reception, Diagnostic and Correctional Center (ERDCC) in Bonne Terre, Missouri. He brings this civil action pursuant to 42 U.S.C. § 1983, naming the Jefferson County Jail and Officer Unknown Adams as defendants. (Docket No. 1 at 2-3). Officer Adams is sued in both his official and individual capacities. (Docket No. 1 at 2). The complaint concerns an alleged assault against plaintiff by Officer Adams. In his “Statement of Claim,” plaintiff asserts that during “the last week of October, 2018, [he] was in a suicide camera cell” in the booking area of the Jefferson County Jail. (Docket No. 1 at 3). He states that he attempted to commit suicide by “trying to swallow a foreign object of

metal.” Officer Adams intervened by grabbing plaintiff and elbowing him in the mouth, busting his lip, and cutting the inside of his lip. Then, Officer Adams took plaintiff “out of that cell” and “elbowed [him] again,” cutting “another spot of the inside of [his] lip with another tooth.” Plaintiff states that “they never gave [him] medical treatment,” but “only took pictures of [his] mouth.” (Docket No. 1 at 4). He does not, however, attribute the lack of medical treatment to Officer Adams.

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Killian v. Jefferson County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/killian-v-jefferson-county-jail-moed-2022.