Maponga v. Hall Park Hotel

CourtDistrict Court, E.D. Texas
DecidedMay 1, 2025
Docket4:25-cv-00051
StatusUnknown

This text of Maponga v. Hall Park Hotel (Maponga v. Hall Park Hotel) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maponga v. Hall Park Hotel, (E.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

STANSLY T. MAPONGA § § v. § NO. 4:25-CV-00051-SDJ-BD § HALL PARK HOTEL, et al. §

MEMORANDUM OPINION AND ORDER Pro se plaintiff Stansly Maponga sued Hall Park Hotel, Hans Ritten, and Marcus Reed, Dkt. 1, and moved to proceed in forma pauperis, Dkt. 2. The court granted that motion but ordered that service be withheld pending screening of the complaint in accordance with 28 U.S.C. § 1915(e)(2)(B). Dkt. 12. Maponga filed an amended complaint as a matter of course. Dkt. 10; see Fed. R. Civ. P. 15(a)(1). The amended complaint does not incorporate the original complaint by reference and therefore supersedes it. New Orleans Ass’n of Cemetery Tour Guides & Cos. v. New Orleans Archdiocesan Cemeteries, 56 F.4th 1026, 1033 (5th Cir. 2023). Maponga’s operative complaint alleges violations of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12182, and the Fair Housing Act (“FHA”), 42 U.S.C. § 3601, breach of contract, unjust enrichment, and intentional infliction of emotional distress, Dkt. 10 at 2; see 28 U.S.C. § 1331 (providing that “[t]he district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States”); id. § 1367(a) (authorizing “supplemental jurisdiction over all other claims,” including state-law claims, “that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy”). After identifying deficiencies in the amended complaint that could result in dismissal, the court will give Maponga another opportunity to amend. SCREENING STANDARD The court must dismiss a complaint filed in forma pauperis if it “[1] is frivolous or malicious; [2] fails to state a claim on which relief may be granted; or [3] seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B). The court, however, must liberally construe a pro se litigant’s pleadings in analyzing them under § 1915(e). See Flanagan v. LaGrone, No. 9:16-CV-00059-MHS, 2016 WL 4163557, at *1 (E.D. Tex. July 6, 2016) (citing Haines v. Kerner, 404 U.S. 519, 520–21 (1972); Perez v. United States, 312 F.3d 191, 194–95 (5th Cir. 2002)). Under § 1915(e)(2)(B)(i), the court must evaluate the complaint for frivolousness or maliciousness. A complaint “duplicative of a pending or previous lawsuit” is malicious. Potts v. Texas, 354 F. App’x 70, 71 (5th Cir. 2009). That is so even when the plaintiff “raised new claims,” so long as those claims “grow out of the same allegations” as were presented in the prior or pending suit. Id. A court may dismiss a duplicative case as either malicious or frivolous. See id.; Silva v. Stickney, No. 3:03-cv-2279-D, 2005 WL 2445433, at *4 (N.D. Tex. Sept. 30, 2005) (explaining that a court “may appropriately dismiss an in forma pauperis action as frivolous, when the action ʻseek[s] to relitigate claims which allege substantially the same facts arising from a common series of events which have already been unsuccessfully litigated by the IFP plaintiff’” (quoting Wilson v. Lynaugh, 878 F.2d 846, 850 (5th Cir. 1989)). Claims without an arguable basis in law or fact are also frivolous. See, e.g., Brewster v. Dretke, 587 F.3d 764, 767 (5th Cir. 2009); see also Moore v. Mabus, 976 F.2d 268, 270 (5th Cir. 1992) (distinguishing between factual and legal frivolousness). A complaint lacks an arguable basis in law when it “is grounded upon an untenable, discredited, or indisputably meritless legal theory, including alleged violations of a legal interest that clearly does not exist.” Brown v. Allen, No. 3:16- cv-214-N-BN, 2016 WL 2855581, at *2 (N.D. Tex. Apr. 25, 2016) (citing Neitzke v. Williams, 490 U.S. 319, 326–27 (1989); Berry v. Brady, 192 F.3d 504, 507 (5th Cir. 1999)). In reviewing claims for legal frivolousness, courts may reject wholly conclusory claims, Bilbrew v. Johnson, 239 F. App’x 49, 51 (5th Cir. 2007), or those that fail to comply with the pleading standard requiring a short and plain statement demonstrating entitlement to relief, Harris v. DOJ, 680 F.2d 1109, 1110 (5th Cir. 1982) (per curiam). When screening for factual frivolousness, the court need not “accept without question the truth of the plaintiff’s allegations[,]” even when the allegations “cannot be rebutted by judicially noticeable facts.” Denton v. Hernandez, 504 U.S. 25, 32 (1992). Instead, if the complaint’s “factual contentions are clearly baseless”—such as “claims describing fantastic or delusional scenarios” or situations that are “wholly incredible”—the court may dismiss the claims sua sponte. Id. at 32–33 (cleaned up). The court also must determine whether any claims not deemed frivolous or malicious “fail[] to state a claim on which relief may be granted” or else “seek[] monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B)(ii)–(iii). The immunity inquiry generally folds into the frivolousness analysis. Cf. Booker v. Koonce, 2 F.3d 114, 116 (5th Cir. 1993) (explaining that “[a] claim against a defendant who is immune from suit is frivolous because it is based upon an indisputably meritless legal theory”). But a defendant’s immunity acts as an independent basis for § 1915(e) dismissal when a plaintiff seeks damages. See Krueger v. Reimer, 66 F.3d 75, 76 (5th Cir. 1995) (per curiam); Boyd v. Bigers, 31 F.3d 279, 284 (5th Cir. 1994) (per curiam). Likewise, the plaintiff’s failure to state a claim alone may serve as a basis for dismissal. 28 U.S.C. § 1915(e)(2)(B)(ii). In determining whether a complaint fails to state a claim on which relief may be granted, and in contrast to the frivolousness analysis, a court must “accept[] all well- pleaded facts as true, viewing them in the light most favorable to the plaintiff.” In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (quotation marks omitted).

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Related

Booker v. Koonce
2 F.3d 114 (Fifth Circuit, 1993)
Berry v. Brady
192 F.3d 504 (Fifth Circuit, 1999)
Perez v. United States
312 F.3d 191 (Fifth Circuit, 2002)
Bilbrew v. Johnson
239 F. App'x 49 (Fifth Circuit, 2007)
Brewster v. Dretke
587 F.3d 764 (Fifth Circuit, 2009)
Potts v. State of Texas
354 F. App'x 70 (Fifth Circuit, 2009)
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)
Harold H. Huggins Realty, Inc. v. FNC, INC.
634 F.3d 787 (Fifth Circuit, 2011)
David Darrell Moore v. Ray Mabus
976 F.2d 268 (Fifth Circuit, 1992)
John Boyd v. Neal B. Biggers, Jr.
31 F.3d 279 (Fifth Circuit, 1994)
In Re Katrina Canal Breaches Litigation
495 F.3d 191 (Fifth Circuit, 2007)
GTE Southwest, Inc. v. Bruce
998 S.W.2d 605 (Texas Supreme Court, 1999)
Fortune Production Co. v. Conoco, Inc.
52 S.W.3d 671 (Texas Supreme Court, 2000)

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Maponga v. Hall Park Hotel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maponga-v-hall-park-hotel-txed-2025.