Moore v. Houwman

CourtDistrict Court, D. South Dakota
DecidedSeptember 9, 2025
Docket4:25-cv-04026
StatusUnknown

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

Bluebook
Moore v. Houwman, (D.S.D. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

JOSHUA M. MOORE, 4:25-CV-04026-KES

Plaintiff, ORDER GRANTING PLAINTIFF’S vs. MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS AND ROBIN HOUWMAN, KARL THOENNES, § 1915 SCREENING, DISMISSING ALISON NELSON, MINNEHAHA ALL CLAIMS COUNTY, JASON KOISTINEN, TRACI SMITH, NICOLE PHILLIPS, LUKE LAWTON, ELISE RASMUSSEN, and DAN HAGGAR,

Defendants.

Plaintiff, Joshua M. Moore, filed a pro se civil rights lawsuit under 42 U.S.C. § 1983 against defendants Judge Robin Houwman, Magistrate Judge Alison Nelson, Karl Thoennes, Jason Koistinen, Traci Smith, Nicole Philips, Luke Lawton, Elise Rasmussen, Dan Haggar, and Minnehaha County, alleging they each violated his Sixth Amendment rights. Docket 10 at 1-4; see also Docket 15. He also moves for leave to proceed in forma pauperis. Docket 2. I. Motion for Leave to Proceed in Forma Pauperis and for Extension of Time

A federal court may authorize the commencement of any lawsuit without prepayment of fees when an applicant submits an affidavit stating he or she is unable to pay the costs of the lawsuit. 28 U.S.C. § 1915(a)(1). “[I]n forma pauperis status does not require a litigant to demonstrate absolute destitution.” Lee v. McDonald’s Corp., 231 F.3d 456, 459 (8th Cir. 2000). Proceeding in forma pauperis under § 1915(a)(1) is a privilege granted at the district court’s discretion. Williams v. McKenzie, 834 F.2d 152, 154 (8th Cir. 1987) (citation omitted); see also Cross v. Gen. Motors Corp., 721 F.2d 1152,

1157 (8th Cir. 1983). Moore’s application to proceed in forma pauperis demonstrates that he has insufficient funds to pay the civil filing fee. Docket 2. Thus, Moore’s motion for leave to proceed in forma pauperis (Docket 2) is granted. Moore also filed a motion for extension of time to comply with timing requirements for his subsequent filings on April 21, 2025. Docket 12. But there are currently no pending deadlines in Moore’s case. Moore’s motion for extension of time (Docket 12) is denied as moot.

The court now screens Moore’s complaint under 28 U.S.C. § 1915. II. § 1915 Screening A. Procedural History Moore filed a complaint on February 24, 2025. Docket 1. Before the complaint was served on defendants, Moore filed an amended complaint. Docket 10. A party may amend its pleading once as a matter of course, no later than 21 days after service. Fed. R. Civ. P. 15(a)(1)(A). Thus, this court will

incorporate facts contained within Moore’s amended complaint into its analysis. Moore also filed a Motion for Leave to File Supplemental Pleadings setting out additional facts and arguments concerning the alleged deprivation of rights described above. Docket 15. The Federal Rules of Civil Procedure provide that “[o]n motion and reasonable notice, the court may, on just terms, permit a party to serve a supplemental pleading setting out any transaction, occurrence, or event that happened after the date of the pleading to be supplemented.” Fed.

R. Civ. P. 15(d) (emphasis added). Moore’s filing appears to be aimed at further clarifying the events before February 24, 2025, the date of his first complaint. Docket 15. This court thus construes this filing to be a motion for leave to file a second amended complaint rather than a motion for leave to file a supplemental pleading. Under the Federal Rules, a party may amend its pleading once as a matter of course. Fed. R. Civ. P. 15(a)(1). All other amendments require leave of the court or the opposing party’s written consent. Fed. R. Civ. P. 15(a)(2). The

Federal Rules also provide that the court should freely give leave to file a second amended pleading when justice so requires. Id; see also Am. Fam. Mut. Ins. v. Hollander, 705 F.3d 339, 348 (8th Cir. 2013) (explaining that leave to amend should be “liberally granted where necessary to bring about the furtherance of justice and where the adverse party will not be prejudiced”) (citation omitted). Here, none of the defendants in this action have consented to Moore’s filing a second amended pleading. But because permitting a second

amended pleading will allow Moore to describe his grievances completely and will not prejudice adverse parties, this court will permit it. Thus, Moore’s motion for leave to file supplemental pleadings (Docket 15) is granted. This court incorporates facts described in Moore’s second amended pleading into its analysis. B. Factual Allegations According to Moore’s amended complaint, he turned himself in at the

Minnehaha County Jail on February 18, 2025, in connection with charges of simple assault. Docket 10 at 4. While there, Moore filled out an application for court–appointed counsel with the Clerk of Courts. Id. Moore was experiencing symptoms of severe bipolar disorder, anxiety, and other mental health issues at the time of this application and was unable to adequately represent himself in court. Id. Moore recognized his need for counsel and attempted to contact the Minnehaha County Public Advocate and Public Defender’s offices to obtain representation. Id. He did not immediately receive representation following

these requests. Id. Over the following week, Moore submitted a letter from his treating physician and a typewritten motion requesting counsel to presiding Second Circuit Judge Robin Houwman. Docket 10 at 5. Moore still did not receive appointed counsel after submitting these materials, and now argues that the resulting need to proceed pro se violated his Sixth Amendment rights. Id. When Moore eventually did receive counsel from the court, he also became aware that

the alleged victim of his assault—Shawn Goetsch—had been represented by the Minnehaha County Public Defender’s Office in various matters for over twenty years. Id. at 5–6; see also Docket 15–2. Moore alleges that the court’s appointment of conflicted counsel violated his Sixth Amendment rights and was pursuant to a “systemic practice of assigning court–appointed counsel without conducting any conflict checks[.]” Docket 15–1 at 3. Judge Houwman is named as a defendant. Docket 10 at 2. Moore also told South Dakota Second Judicial Circuit Administrator Karl

Thoennes that he was concerned about initially proceeding without counsel on February 24, 2025. Id. at 5. According to Moore, Thoennes dismissed Moore’s concerns about proceeding at his initial appearance without counsel and stated that the appointment of counsel before an initial appearance was rare. Id. Moore claims Thoennes’s dismissal of his concerns exacerbated his distress and legal vulnerability. Id. He names Thoennes as a defendant. Id. at 2. The next day, Moore experienced a panic attack when he was due for an initial appearance. Docket 10 at 2. Deputies at the jail witnessed this event,

but the case continued regardless. Id. Moore’s complaint appears to attribute the case’s errantly proceeding to an unofficial policy of Minnehaha County, which he names as a defendant. Id. When Moore became aware that the alleged victim of his assault—Shawn Goetsch—had been represented by the Minnehaha County Public Defender’s Office in various matters for over twenty years, he raised his concerns with the public defender’s office. Id. at 5–6.

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Moore v. Houwman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moore-v-houwman-sdd-2025.