Kynwulf v. Corcoran

CourtDistrict Court, S.D. Ohio
DecidedOctober 2, 2024
Docket2:24-cv-00213
StatusUnknown

This text of Kynwulf v. Corcoran (Kynwulf v. Corcoran) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kynwulf v. Corcoran, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ALFAR KYNWULF,

Plaintiff, : Case No. 2:24-cv-213 v. Chief Judge Sarah D. Morrison Magistrate Judge Chelsey M. Vascura MAUREEN CORCORAN, et al., : Defendants.

OPINION AND ORDER Alfar Kynwulf, proceeding pro se, filed this action against officials of the Ohio Department of Medicaid, the Ohio Department of Job and Family Services, the Butler County Department of Job and Family Services, and the Ohio Attorney General’s Office. (Compl., ECF No. 2.) The suit arises from the denial of a religious exemption on his behalf from Ohio’s Medicaid Estate Recovery provisions. (Id.) Following an initial screen of the Complaint, the Court dismissed all of Mr. Kynwulf’s claims but one, allowing his claim under the First Amendment and 42 U.S.C. § 1983 to proceed. (ECF No. 11.) Now before the Court are three pending motions and two objections to Orders from the Magistrate Judge. Starting with the latter, Mr. Kynwulf’s Objection to the Magistrate Judge’s Order of September 4, 2024 (ECF No. 27) is OVERRULED. Mr. Kynwulf’s Objection, in part, to the Magistrate Judge’s Order of September 25, 2024 (ECF No. 32) is also OVERRULED. The first pending motion (ECF No. 17) is Mr. Kynwulf’s motion asking the Court to reconsider its denial of one of his previous motions for reconsideration. That motion is DENIED.

The second pending motion (ECF No. 19) is a Motion to Dismiss filed by Defendants Jamie Wilkinson, Katelynn Hart, and John and/or Jane Doe of the Butler County Department of Job and Family Services (collectively, the “Butler County Defendants”). This Motion to Dismiss is HELD IN ABEYANCE, as discussed below. The third pending motion (ECF No. 33) is Mr. Kynwulf’s motion seeking to compel the Court to issue a scheduling order pursuant to Federal Rule of Civil

Procedure 16. That motion is DENIED. I. STANDARD OF REVIEW

Federal Rule of Civil Procedure 8(a) requires a plaintiff to plead each claim with sufficient specificity to “give the defendant fair notice of what the ... claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal quotations omitted). A complaint which falls short of the Rule 8(a) standard may be dismissed if it fails to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). When evaluating a Rule 12(b)(6) motion to dismiss, courts must construe the complaint in the light most favorable to the plaintiff and accept the complaint’s allegations as true, drawing all reasonable inferences in favor of the plaintiff. Coley v. Lucas Cty., Ohio, 799 F.3d 530, 537 (6th Cir. 2015); Directv, Inc. v. Treesh, 487 F.3d 471, 476 (6th Cir. 2007). The complaint need not contain detailed factual allegations, but it must include more than labels, conclusions, and formulaic recitations of the elements of a cause of action. Directv, at 476. “Threadbare recitals

of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 555). To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. 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. The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are merely consistent with a defendant’s liability, it stops short of the line between possibility and plausibility of entitlement to relief.

Id. (internal citations and quotation marks omitted). These standards also apply when the plaintiff is pro se. Although a pro se litigant is entitled to a liberal construction of his pleadings and filings, he still must do more than assert bare legal conclusions, and the “complaint must contain either direct or inferential allegations respecting all the material elements to sustain a recovery under some viable legal theory.” Mezibov v. Allen, 411 F.3d 712, 716 (6th Cir. 2005). Every plaintiff, regardless of whether they have counsel, “must allege, with particularity, facts that demonstrate what each defendant did to violate the asserted constitutional right.” Lanman v. Hinson, 529 F.3d 673, 684 (6th Cir. 2008) (emphasis in original). “While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations.” Iqbal, 556 U.S. at 679. II. ANALYSIS To state a claim under 42 U.S.C. § 1983, a plaintiff must (1) allege the violation of a right secured by the federal Constitution or laws, and (2) show that

the deprivation was committed by a person acting under color of state law. West v. Atkins, 487 U.S. 42, 48 (1988); Street v. Corr. Corp. of Am., 102 F.3d 810, 814 (6th Cir. 1996). A complaint may be dismissed for failure to state a claim if it fails “to give the defendant fair notice of what the ... claim is and the grounds upon which it rests.” Twombly, 550 U.S. at 555 (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). “Persons sued in their individual capacities under § 1983 can be held liable based only on their own unconstitutional behavior.” Heyerman v. Cnty. of Calhoun,

680 F.3d 642, 647 (6th Cir. 2012); see generally Hardin v. Straub, 954 F.2d 1193, 1999 (6th Cir. 1992) (explaining differences between official and individual capacity § 1983 suits). Personal liability “must be based on actions of that defendant” and “not based on any problems caused by the errors of others.” Gibson v. Matthews, 926 F.2d 532, 535 (6th Cir. 1991). And to plead a claim against a county, a plaintiff must plausibly allege that his constitutional deprivation occurred as a result of an

official policy or custom. See Smith v. City of Troy, Ohio, 874 F.3d 938, 946 (6th Cir. 2017). Where a person is named as a defendant without an allegation of specific conduct, the complaint is subject to dismissal, even under the liberal construction afforded to pro se complaints. See Gilmore v. Corr. Corp. of Am., 92 F. App’x 188, 190 (6th Cir.

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Heyerman v. County of Calhoun
680 F.3d 642 (Sixth Circuit, 2012)
Lanman v. Hinson
529 F.3d 673 (Sixth Circuit, 2008)
Denise Coley v. Lucas County, Ohio
799 F.3d 530 (Sixth Circuit, 2015)
Victor Smith v. City of Troy, Ohio
874 F.3d 938 (Sixth Circuit, 2017)
Frazier v. State of Michigan
41 F. App'x 762 (Sixth Circuit, 2002)
Gilmore v. Corrections Corp.
92 F. App'x 188 (Sixth Circuit, 2004)
Gibson v. Matthews
926 F.2d 532 (Sixth Circuit, 1991)
Hall v. Bellmon
935 F.2d 1106 (Tenth Circuit, 1991)

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Kynwulf v. Corcoran, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kynwulf-v-corcoran-ohsd-2024.