Lammers v. County of Phelps, NE

CourtDistrict Court, D. Nebraska
DecidedApril 25, 2025
Docket8:24-cv-00198
StatusUnknown

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

Bluebook
Lammers v. County of Phelps, NE, (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

JESS T. LAMMERS,

Plaintiff, 8:24CV198

vs. MEMORANDUM AND ORDER COUNTY OF PHELPS, NE, NATALIE NELSON, Attorney; SHAWN EATHERTON, HOLDREGE POLICE DEPARTMENT, LELAND RODEWALD, PO; COUNTY OF PHELPS SHERRIF, JAMIE TILSON, (Deputy); and MAGISTRATE STREETER,

Defendants.

Plaintiff Jess T. Lammers (“Plaintiff” or “Lammers”), who advised he is no longer incarcerated, filed a Motion for Leave to Proceed in Forma Pauperis. Filing No. 10. Upon review of Plaintiff’s motion, the Court finds that Plaintiff is financially eligible to proceed in forma pauperis as a non-prisoner. The Court will now conduct an initial review of Plaintiff’s Complaint, Filing No. 1, pursuant to 28 U.S.C. § 1915(e)(2). I. SUMMARY OF COMPLAINT Plaintiff filed his Complaint on May 30, 2024, against Phelps County, Nebraska, attorney Natalie Nelson, attorney Shawn Eatherton (“Eatherton”), the Holdrege Police Department (“HPD”), HPD officer Leland Rodewald (“Officer Rodewald”), Phelps County Sheriff Deputy Jamie Tilson (“Deputy Tilson”), and Magistrate Streeter. Plaintiff alleges on April 2, 2024, he went to 208 Blaine Street in Holdrege, Nebraska, to retrieve legal documents and personal property and “was assaulted by Russel Wright [(“Wright”)], a habitual criminal and felon.” Filing No. 1 at 2. Prior to Plaintiff’s arrival at the Blaine Street address, Wright forged Plaintiff’s signature on “certificate of service” documents with Deputy Tilson in front of Magistrate Streeter at the Phelps County Courthouse, which Plaintiff’s probation officer witnessed. Id. at 1. In the assault, Wright beat Plaintiff unconscious with Plaintiff’s cane. Plaintiff was treated at Phelps Memorial Emergency Room (“ER”) for his injuries and alleges the following with respect to events following the assault:

[Deputy Tilson] aided in the forgery and assault. Leland Rodewald, Holdrege Police Department, was at 208 Blaine St. then took Lammers’ report at ER. Lammers has a witness Jen Seely. Subsequently, Shawn Eatherton was appointed special prosecutor. However, [Eatherton] will not give Lammers, the victim, the police reports or body or car camera footage. The County of Phelps and special prosecutor refuse to prosecute Wright for 1st degree assault, forgery, use of a weapon to commit a felony, and possession of a weapon by a prohibited person. Magistrate Streeter witness to the forgery is an accessory after the fact because of her silence.

Id. at 2 (punctuation and capitalization corrected). As relief, Plaintiff asks the Court to issue a writ of mandamus under 28 U.S.C. § 1361 ordering Eatherton to file criminal charges against Wright, Officer Rodewald, Deputy Tilson, and Magistrate Streeter. II. STANDARDS ON INITIAL REVIEW The Court is required to review in forma pauperis complaints to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). The Court must dismiss a complaint or any portion of it that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). “The essential function of a complaint under the Federal Rules of Civil Procedure is to give the opposing party ‘fair notice of the nature and basis or grounds for a claim, and a general indication of the type of litigation involved.’” Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 848 (8th Cir. 2014) (quoting Hopkins v. Saunders, 199 F.3d 968, 973 (8th Cir. 1999)). Plaintiffs must set forth enough factual allegations to “nudge[ ] their claims across the line from conceivable to plausible,” or “their complaint must be dismissed.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 569-70 (2007); see also Ashcroft v. Iqbal, 556 U.S. 662, 678 (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.”). “A pro se complaint must be liberally construed, and pro se litigants are held to a lesser pleading standard than other parties.” Topchian, 760 F.3d at 849 (internal quotation marks and citations omitted). This means that “if the essence of an allegation is discernible, even though it is not pleaded with legal nicety, then the district court should construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework.” Stone v. Harry, 364 F.3d 912, 915 (8th Cir. 2004). 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). III. DISCUSSION Liberally construed, Plaintiff asks this Court to issue a writ of mandamus compelling Phelps County special prosecutor Eatherton to initiate state criminal proceedings against certain individuals. A federal district court is authorized to issue writs of mandamus or other extraordinary writs only in aid of its jurisdiction, either existing or potential. See 28 U.S.C. § 1651(a); Middlebrooks v. Thirteenth Judicial Dist. Circuit Court, Union Cnty., 323 F.2d 485, 486 (8th Cir. 1963). The writ of mandamus is an extraordinary remedy, and therefore must be issued only in extraordinary circumstances. “In order to insure that the writ will issue only in extraordinary circumstances [the United States Supreme Court] has required that a party seeking issuance have no other adequate means to attain the relief he desires, and that he satisfy the burden of showing that his right to issuance of the writ is clear and indisputable.” Allied Chemical Corp. v. Daiflon, Inc., 449 U.S. 33, 35 (1980) (citations and internal quotations omitted).

The actions of Eatherton and the other named defendants in the instant case are not within the jurisdiction of this Court. See Middlebrooks, 323 F.2d at 486. Specifically, this Court has no authority to compel action by county prosecutors. See 28 U.S.C. § 1361 (“The district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff.”) (emphasis added); see also Veneri v. Circuit Court of Gasconade Cnty., 528 F.Supp. 496, 498 (E. D. Mo.

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Related

Allied Chemical Corp. v. Daiflon, Inc.
449 U.S. 33 (Supreme Court, 1980)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Veneri v. Circuit Court of Gasconade County
528 F. Supp. 496 (E.D. Missouri, 1981)
Samvel Topchian v. JPMorgan Chase Bank, N.A.
760 F.3d 843 (Eighth Circuit, 2014)
Tommy Hopkins v. John Saunders
199 F.3d 968 (Eighth Circuit, 1999)
Martin v. Aubuchon
623 F.2d 1282 (Eighth Circuit, 1980)

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Lammers v. County of Phelps, NE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lammers-v-county-of-phelps-ne-ned-2025.