Lott v. Ohio Bar Association

CourtDistrict Court, S.D. Ohio
DecidedJuly 18, 2022
Docket2:22-cv-02219
StatusUnknown

This text of Lott v. Ohio Bar Association (Lott v. Ohio Bar Association) 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
Lott v. Ohio Bar Association, (S.D. Ohio 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

HARRY WILLIAM LOTT, EX PARTE,

Plaintiff, Case No. 2:22-CV-2219

vs. Chief Judge Algenon L. Marbley

Magistrate Judge Elizabeth P. Deavers OHIO BAR ASSOCIATION,

Defendant.

ORDER AND INITIAL SCREEN REPORT AND RECOMMENDATION

Plaintiff, an Ohio resident who is proceeding without the assistance of counsel, initiated this action on May 19, 2022. (ECF No. 1.) The Court granted Plaintiff’s request to proceed in forma pauperis and deferred the initial screen. (ECF No. 11.) This matter is now before the Court for the initial screen of Plaintiff’s Complaint under 28 U.S.C. § 1915(e)(2) to identify cognizable claims and to recommend dismissal of Plaintiff’s Complaint, or any portion of it, which is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). Having performed the initial screen, for the reasons that follow, it is RECOMMENDED that the Court DISMISS Plaintiff’s action in its entirety. I. Congress enacted 28 U.S.C. § 1915, the federal in forma pauperis statute, seeking to “lower judicial access barriers to the indigent.” Denton v. Hernandez, 504 U.S. 25, 31 (1992). In doing so, however, “Congress recognized that ‘a litigant whose filing fees and court costs are assumed by the public, unlike a paying litigant, lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits.’” Id. at 31 (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To address this concern, Congress included subsection (e)1 as part of the statute, which provides in pertinent part: (2) Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that--

* * *

(B) the action or appeal--

(i) is frivolous or malicious;

(ii) fails to state a claim on which relief may be granted; or . . . .

28 U.S.C. § 1915(e)(2)(B)(i) & (ii); Denton, 504 U.S. at 31. Thus, § 1915(e) requires sua sponte dismissal of an action upon the Court’s determination that the action is frivolous or malicious, or upon determination that the action fails to state a claim upon which relief may be granted. To properly state a claim upon which relief may be granted, a plaintiff must satisfy the basic federal pleading requirements set forth in Federal Rule of Civil Procedure 8(a). See also Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (applying Federal Rule of Civil Procedure 12(b)(6) standards to review under 28 U.S.C. §§ 1915A and 1915(e)(2)(B)(ii)). Under Rule 8(a)(2), a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Thus, Rule 8(a) “imposes legal and factual demands on the authors of complaints.” 16630 Southfield Ltd., P’Ship v. Flagstar Bank, F.S.B., 727 F.3d 502, 503 (6th Cir. 2013).

1Formerly 28 U.S.C. § 1915(d). Although this pleading standard does not require “‘detailed factual allegations,’ . . . [a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action,’” is insufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). A complaint will not “suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557).

Instead, to survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a complaint must contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). Facial plausibility is established “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. “The plausibility of an inference depends on a host of considerations, including common sense and the strength of competing explanations for the defendant’s conduct.” Flagstar Bank, 727 F.3d at 504 (citations omitted). Further, the Court holds pro se complaints “‘to less stringent standards than formal pleadings drafted by lawyers.’” Garrett v. Belmont Cnty. Sheriff’s Dep’t., No. 08-3978, 2010 WL 1252923, at *2 (6th Cir. April

1, 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). This lenient treatment, however, has limits; “‘courts should not have to guess at the nature of the claim asserted.’” Frengler v. Gen. Motors, 482 F. App’x 975, 976–77 (6th Cir. 2012) (quoting Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989)). II. Plaintiff’s Complaint and “Motion to Amended Supplemental Pleading, Motion to Disqualify” consist largely of quotes and citations to various United States Supreme Court cases, constitutional amendments and Latin legal terms. As best the undersigned can discern, Plaintiff apparently applied for an Ohio law license which the Supreme Court of Ohio denied. (ECF No. 1-1 at PageID 16.) The Supreme Court explained as follows: The Office of Bar Admissions is returning your Applicant's Supplemental Character Questionnaire and other related documents because you do not meet the requirements of Rule I of the Supreme Court Rules for the Government of the Bar of Ohio ("Gov. Bar R. I"). Please note that Article IV, Section 2(B)(1)(g) of the Ohio Constitution grants the Supreme Court of Ohio exclusive jurisdiction to regulate admission to the practice of law in Ohio. The Ohio Supreme Court exercises this jurisdiction pursuant to Rule I of the Rules of the Government of the Bar.

Gov. Bar R. I, Sec. 1, clearly states that whether you are applying to sit for the Ohio Bar Examination, applying for Admission Without Examination, applying to transfer a UBE score or applying for any other form of admission, an applicant for admission to the Ohio Bar must have earned a bachelor's degree from an accredited college or university and must have earned a J.D. from a law school approved by the American Bar Association.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Neil Frengler v. General Motors
482 F. App'x 975 (Sixth Circuit, 2012)
Robert v. Tesson
507 F.3d 981 (Sixth Circuit, 2007)
Pfahler v. National Latex Products Co.
517 F.3d 816 (Sixth Circuit, 2007)
United States v. Sullivan
431 F.3d 976 (Sixth Circuit, 2005)
Robert Davis v. Ruth Johnson
664 F. App'x 446 (Sixth Circuit, 2016)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)

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Lott v. Ohio Bar Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lott-v-ohio-bar-association-ohsd-2022.