Maxwell Brunken v. Dr. Andrea Nillas

CourtDistrict Court, N.D. Texas
DecidedSeptember 30, 2025
Docket3:25-cv-02292
StatusUnknown

This text of Maxwell Brunken v. Dr. Andrea Nillas (Maxwell Brunken v. Dr. Andrea Nillas) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maxwell Brunken v. Dr. Andrea Nillas, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION MAXWELL BRUNKEN, § § Plaintiff, § § V. § No. 3:25-cv-2292-N-BN § DR. ANDREA NILLAS, § § Defendant. § FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE Plaintiff Maxwell Brunken filed this pro se action against Dr. Andrea Nillas, an emergency room physician at UT Southwestern Medical Center. See Dkt. No. 3. Senior United States District Judge David C. Godbey referred this lawsuit to the undersigned United States magistrate judge for pretrial management under 28 U.S.C. § 636(b) and a standing order of reference. By separate order, the Court will grant Brunken leave to proceed in forma pauperis (“IFP”). And the undersigned enters these findings of fact, conclusions of law, and recommendation that the Court should dismiss this lawsuit with prejudice. Legal Standards A district court is required to screen a civil complaint filed IFP (that is, without payment of the filing fee) and may summarily dismiss that complaint (or any portion of it) if the complaint fails to state a claim on which relief may be granted. See 28 U.S.C. § 1915(e)(2)(B)(ii). “The language of § 1915(e)(2)(B)(ii) tracks the language of Federal Rule of Civil Procedure 12(b)(6).” Black v. Warren, 134 F.3d 732, 733-34 (5th Cir. 1998) (per curiam). And “[i]t is well-established that a district court may dismiss a complaint on

its own motion under [Rule] 12(b)(6) for failure to state a claim upon which relief may granted.” Starrett v. U.S. Dep’t of Defense, No. 3:18-cv-2851-M-BH, 2018 WL 6069969, at *1 (N.D. Tex. Oct. 30, 2018) (citing Carroll v. Fort James Corp., 470 F.3d 1171 (5th Cir. 2006)), rec. accepted, 2018 WL 6068991 (N.D. Tex. Nov. 20, 2018), aff’d, 763 F. App’x 383 (5th Cir.) (per curiam), cert. denied, 140 S. Ct. 142 (2019). A district court may exercise its “inherent authority ... to dismiss a complaint on its own motion ... ‘as long as the procedure employed is fair.’” Gaffney v. State Farm

Fire & Cas. Co., 294 F. App’x 975, 977 (5th Cir. 2008) (per curiam) (quoting Carroll, 470 F.3d at 1177; citation omitted). “[F]airness in this context requires both notice of the court’s intention to dismiss sua sponte and an opportunity to respond.” Id. (cleaned up; quoting Lozano v. Ocwen Fed. Bank, FSB, 489 F.3d 636, 643 (5th Cir. 2007)); see also Carver v. Atwood, 18 F.4th 494, 498 (5th Cir. 2021) (“The broad rule is that ‘a district court

may dismiss a claim on its own motion as long as the procedure employed is fair.’ More specifically, ‘fairness in this context requires both notice of the court’s intention and an opportunity to respond’ before dismissing sua sponte with prejudice.” (citations omitted)). And these findings, conclusions, and recommendations provide notice, while the period for filing objections affords an opportunity to respond. See, e.g., Starrett, 2018 WL 6069969, at *2 (citations omitted). A district court’s authority to dismiss an action that “fails to ‘state a claim for relief that is plausible on its face’” extends to dismissal of “claims that are ‘clearly

baseless,’ including ‘claims describing fantastic or delusional scenarios.’” Starrett, 763 F. App’x at 383-84 (quoting Twombly, 550 U.S. at 570, then Neitzke v. Williams, 490 U.S. 319, 327-28 (1989); citing Denton v. Hernandez, 504 U.S. 25, 33 (1992) (concluding that dismissal “is appropriate when the facts alleged rise to the level of the irrational or the wholly incredible, whether or not there are judicially noticeable facts available to contradict them”)). Analysis

This is one of three lawsuits related to the same events that Brunken has filed. See Brunken v. Truong, No. 3:25-cv-2290-B-BN (N.D. Tex.); Brunken v. Univ. of Tex. Southwestern Med. Ctr., No. 3:25-cv-2291-D-BN (N.D. Tex.). The first lawsuit was brought against the individuals who allegedly performed the medical procedure at issue in the three cases. This case is brought against the emergency room doctor who allegedly requested a consultation and later prescribed medication. See Dkt. No. 3 at

2-3. Brunken asserts seven claims in this lawsuit. Two of the claims he alleges – Counts V and VI – do not give rise to a private right of action. Count V purports to allege a claim under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and Count VI purports to allege a claim under 18 U.S.C. § 1519, a criminal law relating to the destruction, alteration, or falsification of records a matter within the jurisdiction of a United States department or agency or a bankruptcy case. But, while HIPAA provides a mechanism for the Secretary of Health and Human Services to seek civil and criminal penalties, it does not give rise to a private

right of action. See Acara v. Banks, 470 F.3d 569, 571-72 (5th Cir. 2006) (per curiam). And, in addition to the criminal statute not having any relevance to the facts alleged by Brunken, “[p]rivate citizens do not have the right to bring a private action under a federal criminal statute.” See Pierre v. Guidry, 75 F. App’x. 300, 301 (5th Cir. 2003) (per curiam). For a private right of action to exist, there must be “a statutory basis for inferring that a civil cause of action of some sort lay in favor of someone.” Cort v. Ash, 422 U.S. 66, 79 (1975), overruled in part by Touche Ross & Co. v. Redington, 442

U.S. 560 (1979); see also Suter v. Artist M., 503 U.S. 347, 363 (1992) (the party seeking to imply a private right of action bears the burden to show that Congress intended to create one). So Brunken has not stated a claim in Counts V and VI. The remaining five claims are for alleged violations of constitutional rights under 42 U.S.C. § 1983. And three of the five (Counts I, III, and IV) are for substantive

due process violations. But for non-legislative substantive due process claims, “only the most egregious official conduct can be said to be ‘arbitrary in the constitutional sense.’” County of Sacramento v. Lewis, 523 U.S. 833, 846 (1998) (quoting Collins v. Harker Heights, 503 U.S. 115, 129 (1992)). Substantive due process is not meant to duplicate common-law tort liability “but rather points clearly away from liability, or clearly toward it, only at the ends of the tort law’s spectrum of culpability.” Id. at 848. It “does not entail a body of constitutional law imposing liability whenever someone cloaked with state authority causes harm,” but requires action that “rise[s] to the conscience-shocking level.” Id. at 848-49. Brunken’s allegations do not meet the high

standard required to establish a violation of substantive due process.

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Related

Black v. Warren
134 F.3d 732 (Fifth Circuit, 1998)
McKinney v. Irving Independent School District
309 F.3d 308 (Fifth Circuit, 2002)
Acara v. Banks
470 F.3d 569 (Fifth Circuit, 2006)
Lozano v. Ocwen Federal Bank, FSB
489 F.3d 636 (Fifth Circuit, 2007)
Gaffney Ex Rel. Gaffney v. State Farm Fire & Casualty Co.
294 F. App'x 975 (Fifth Circuit, 2008)
Oyler v. Boles
368 U.S. 448 (Supreme Court, 1962)
Cort v. Ash
422 U.S. 66 (Supreme Court, 1975)
Touche Ross & Co. v. Redington
442 U.S. 560 (Supreme Court, 1979)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Collins v. City of Harker Heights
503 U.S. 115 (Supreme Court, 1992)
Suter v. Artist M.
503 U.S. 347 (Supreme Court, 1992)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
County of Sacramento v. Lewis
523 U.S. 833 (Supreme Court, 1998)
Christopher v. Harbury
536 U.S. 403 (Supreme Court, 2002)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Wren Thomas v. Chevron USA, Incorporated
832 F.3d 586 (Fifth Circuit, 2016)
Scott v. U.S. Bank National Assn
16 F.4th 1204 (Fifth Circuit, 2021)

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Bluebook (online)
Maxwell Brunken v. Dr. Andrea Nillas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maxwell-brunken-v-dr-andrea-nillas-txnd-2025.