Mitchell v. Pate (INMATE 3)

CourtDistrict Court, M.D. Alabama
DecidedSeptember 14, 2022
Docket2:22-cv-00358
StatusUnknown

This text of Mitchell v. Pate (INMATE 3) (Mitchell v. Pate (INMATE 3)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mitchell v. Pate (INMATE 3), (M.D. Ala. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

LONNIE DONTAE MITCHELL, ) ) Plaintiff, ) ) Civil Action No. v. ) 2:22-cv-358-WHA-CSC ) (WO) KELLY FITZGERALD PATE, et al., ) ) Defendants. )

RECOMMENDATION OF THE MAGISTRATE JUDGE This Bivens action1 is before the court on the amended complaint of Lonnie Dontae Mitchell, a federal defendant awaiting sentencing. Doc. 4.2 Mitchell alleges that United States Magistrate Judge Kelly Fitzgerald Pate and Attorney Preston L. Presley violated his Fourteenth and Sixth Amendment rights. Id. at 1. He seeks damages for $3.5 million. Id. at 2.

1 Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). A “Bivens action” is a suit for damages against a federal actor who, acting in his or her individual capacity under color of federal law, is alleged to have violated the plaintiff’s constitutional rights. Bivens, 403 U.S. at 397; see Butz v. Economou, 438 U.S. 478, 498–99 (1978). The standards of liability in Bivens actions are similar to the standards under 42 U.S.C. § 1983. Butz, 438 U.S. at 500; Abate v. S. Pac. Transp. Co., 993 F.2d 107, 110 n.14 (5th Cir. 1993).

2 References to documents docketed in this Bivens action are designated as “Doc.” References to document numbers in Mitchell’s criminal case in this court, Case No. 2:21cr344-RAH-KFP, are designated as “Crim. Doc.” All pinpoint citations are to the pages of the electronically filed documents in the court’s CM/ECF filing system, which may not correspond to pagination on the hard copies of the documents presented for filing. I. STANDARD OF REVIEW The Prison Litigation Reform Act, 28 U.S.C. § 1915A, requires this Court to screen

complaints filed by prisoners against government officers or employees. 28 U.S.C. § 1915A. The Court must dismiss the complaint or any portion thereof that it finds (1) is frivolous or malicious, (2) fails to state a claim upon which relief may be granted, or (3) seeks monetary relief against a defendant immune from such relief. See 28 U.S.C. § 1915(e)(2)(B) and § 1915(A). The Court may sua sponte dismiss a prisoner’s complaint before service. See 28 U.S.C. § 1915A(a).

Under §1915(A)(b)(1) and § 1915(e)(2)(B)(i), a claim may be dismissed as “frivolous where it lacks an arguable basis in law or fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). A claim is frivolous as a matter of law where, among other things, the defendants are immune from suit, id. at 327, the claim seeks to enforce a right that clearly does not exist, id., or an affirmative defense would defeat the claim, such as the statute of

limitations, Clark v. Georgia Pardons & Paroles Bd., 915 F.2d 636, 640 n.2 (11th Cir. 1990). Courts are accorded “not only the authority to dismiss [as frivolous] a claim based on indisputably meritless legal theory, but also the unusual power to pierce the veil of the complaint’s factual allegations and dismiss those claims whose factual contentions are clearly baseless.” Neitzke, 490 U.S. at 327.

A complaint may be dismissed under § 1915A(b)(1) for failure to state a claim upon which relief may be granted. A review on this ground is governed by the same standards as dismissals for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). See Jones v. Bock, 549 U.S. 199, 215 (2007); Leal v. Georgia Dep’t of Corr., 254 F.3d 1276, 1278–79 (11th Cir. 2001) (noting that the language in § 1915A(b)(1) mirrors the language in 28 U.S.C. § 1915(e)(2)(B)(ii), which tracks the language in Rule 12(b)(6)).

To state a claim upon which relief may be granted, “a complaint must 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) (internal quotation omitted). That is, “[f]actual allegations must be enough to raise a right to relief above the speculative level” and must be a “‘plain statement’ possess[ing] enough heft to ‘sho[w] that the pleader is entitled to relief.’” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 557 (2007) (second

brackets in original). But “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Similarly, when a successful affirmative defense, such as the applicable statute of limitations, appears on the face of a complaint, dismissal for failure to state a claim is also warranted. Jones, 549 U.S. at 215.

A pro se pleading “is held to a less stringent standard than a pleading drafted by an attorney” and is liberally construed. Jones v. Fla. Parole Comm’n, 787 F.3d 1105, 1107 (11th Cir. 2015). However, such pleadings still must allege factual allegations that “raise a right to relief above the speculative level.” Saunders v. Duke, 766 F.3d 1262, 1266 (11th Cir. 2014) (internal quotation marks omitted).

II. MITCHELL’S AMENDED COMPLAINT Mitchell alleges that in May 2022, U.S. Magistrate Judge Kelly Fitzgerald Pate and Attorney Preston L. Presley violated his Fourteenth and Sixth Amendment rights. Doc. 4 at 1. Judge Pate entered orders and other pretrial rulings as the Magistrate Judge in Mitchell’s criminal case in the U.S. District Court for the Middle District of Alabama, where, in June 2022, a jury found Mitchell guilty of multiple counts of sex trafficking.3

See United States v. Mitchell, Case No. 2:21cr344-RAH-KFP; Crim. Doc. 237. Presley is Mitchell’s defense counsel in the criminal case. Sentencing in the case is set for November 2022. See Crim. Doc. 257. In his amended complaint (Doc. 4), Mitchell points to no specific acts by Judge Pate or Presley. In his original complaint, which was superseded by his amended complaint, Mitchell states that Presley filed a motion to withdrew as his counsel in the criminal case

in May 2022, and that Judge Pate initially granted that motion but later, after continuing the matter for further consideration, denied the motion. Doc. 1 at 1. Mitchell alleges that these pretrial rulings violated his Sixth Amendment rights to a speedy trial and conflict- free counsel in addition to his rights to due process and equal protection. Id. According to Mitchell, the rulings of Judge Pate caused him emotional and psychological distress and

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Mitchell v. Pate (INMATE 3), Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-pate-inmate-3-almd-2022.