Marchant v. Richardson

CourtDistrict Court, D. Idaho
DecidedJune 3, 2022
Docket1:22-cv-00021
StatusUnknown

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

Bluebook
Marchant v. Richardson, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

BRUCE A. MARCHANT, Case No. 1:22-cv-00021-BLW Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

WARDEN TIM RICHARDSON; DEWAYNE SHEDD; and ATTORNEY DAVID SMETHERS,

Defendant.

The Clerk of Court conditionally filed Plaintiff Bruce A. Marchant’s Complaint as a result of Plaintiff’s status as an inmate and in forma pauperis request. The Court now reviews the Complaint to determine whether it should be summarily dismissed in whole or in part under 28 U.S.C. §§ 1915 and 1915A. Having reviewed the record, and otherwise being fully informed, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed. 1. Pleading Standards and Screening Requirement 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). Under modern pleading standards, Rule 8 requires a complaint to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v.

Twombly, 550 U.S. 544, 570 (2007)). The Iqbal/Twombly “facial plausibility” standard is met when a complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Id. (citing Twombly, 550 U.S. at 556). “[D]etailed factual allegations” are not required, but a plaintiff must offer “more than ... unadorned, the-defendant- unlawfully-harmed-me accusation[s].” Id. (internal quotation marks omitted). If the facts pleaded are “merely consistent with a defendant’s liability,” or if

there is an “obvious alternative explanation” that would not result in liability, the complaint has not stated a claim for relief that is plausible on its face. Id. at 678, 682 (internal quotation marks omitted). Bare allegations that amount to a mere

restatement of the elements of a cause of action, without adequate factual support, are not enough. The Prison Litigation Reform Act (“PLRA”)1 requires that the Court review complaints filed by prisoners seeking relief against a governmental entity or an

officer or employee of a governmental entity, as well as complaints filed in forma pauperis, to determine whether summary dismissal is appropriate. 28 U.S.C.

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq. §§ 1915 & 1915A. The Court must dismiss any claims that do not have adequate factual support or are frivolous or malicious. 28 U.S.C. §§ 1915(e)(2) & 1915A.

The Court also must dismiss claims that fail to state a claim upon which relief may be granted or that seek monetary relief from a defendant who is immune from such relief. Id. These last two categories—together with claims that fall

outside a federal court’s narrow grant of jurisdiction—encompass those claims that might, or might not, have factual support but nevertheless are barred by a well- established legal rule. The Court liberally construes the pleadings to determine whether a case

should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable factual

and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000) (stating that Rule 12(b)(6) authority to dismiss claims was expanded by the PLRA,

giving courts power to dismiss deficient claims, sua sponte, before or after opportunity to amend). Moreover, even if a complaint meets the pleading requirements, dismissal under §§ 1915 and 1915A is still appropriate if an

affirmative defense, such as untimeliness, is an “obvious bar to securing relief on the face of the complaint.” Washington v. Los Angeles Cty. Sheriff’s Dep’t, 833 F.3d 1048, 1056 (9th Cir. 2016) (internal quotation marks omitted).

2. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction, currently incarcerated at the Idaho Maximum Security Institution (“IMSI”). Plaintiff claims that, when he was first placed in the Ada County Jail, in 2016,

unidentified jail deputies confiscated his Bible. Plaintiff also claims that, in late 2019 or early 2020, Defendant Shedd, the IMSI paralegal, shredded several documents that Plaintiff planned to file with the

courts. Plaintiff states that these documents were civil rights complaints and habeas corpus petitions. Finally, Plaintiff asserts several constitutional violations that allegedly occurred in his underlying criminal proceedings. Plaintiff was initially charged

with kidnapping, rape, and first-degree murder. He pleaded guilty to first-degree murder in exchange for dismissal of the other charges. See State v. Marchant, Ada County Case No. CR01-16-41273, docket available at https://icourt.idaho.gov/

(accessed April 6, 2022). Plaintiff received a fixed life sentence. See State v. Marchant, No. 46139, 2019 WL 1057092 (Idaho Ct. App. Mar. 6, 2019) (unpublished). Plaintiff names as Defendants the warden of the prison in which he is confined, former prison paralegal Shedd, and Plaintiff’s criminal defense attorney.

3. Discussion Plaintiff has not alleged sufficient facts to proceed with the Complaint. The Court will, however, grant Plaintiff 60 days to amend the Complaint. Any amended complaint should take into consideration the following.

A. Standards of Law Applicable to Plaintiff’s Claims Plaintiff brings his claims under 42 U.S.C. § 1983, the civil rights statute. To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by

conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). Prison officials generally are not liable for damages in their individual

capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach Government official, his or her title notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does

not allow for recovery against an employer or principal simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045. However, “[a] defendant may be held liable as a supervisor under § 1983 ‘if there exists ... a sufficient causal connection between the supervisor’s wrongful

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Marchant v. Richardson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marchant-v-richardson-idd-2022.