O'Bannon v. Commonwealth of Kentucky

CourtDistrict Court, W.D. Kentucky
DecidedFebruary 24, 2025
Docket3:25-cv-00062
StatusUnknown

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

Bluebook
O'Bannon v. Commonwealth of Kentucky, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION ANTONIO LEE O’BANNON PLAINTIFF v. CIVIL ACTION NO. 3:25-CV-62-JHM COMMONWEALTH OF KENTUCKY et al. DEFENDANT MEMORANDUM OPINION AND ORDER Plaintiff Antonio Lee O’Bannon initiated the instant pro se 42 U.S.C. § 1983 civil-rights action. Upon consideration of Plaintiff’s application to proceed without prepayment of fees, IT IS ORDERED that the application (DN 3) is GRANTED. Because Plaintiff is proceeding in forma pauperis, the Court must screen this action pursuant to 28 U.S.C. § 1915(e)(2). For the following reasons, the action will be dismissed. I. Plaintiff indicates that he is detained at the Kentucky Correctional Psychiatric Center (KCPC).1 He sues the Commonwealth of Kentucky and “KCPC Commissioner” Randy White in his official and individual capacities.2

In the complaint, Plaintiff first references the Ex Post Facto clauses of the United States and Kentucky Constitutions. He asserts that they prohibit “the retroactive application of HB 310 to offenses that occurred prior to April 1, 2021.” Plaintiff states: HB 310 creates a quasi-criminal statutory scheme in KRS Chapter 202C that be applied to qualifying offenses that occurred prior to April 1, 2021. In my case, I was arrested on 1/29/2021 when the 202C law came about on April 2, 2021. There is no retroactive card on the 202C Law or HB 310 isn’t retroactive. And my arrest occurred prior to April 1 2021 HB 310 KRS chapter 202C. 1 Based upon filings made in other actions brought by Plaintiff in this Court, it appears that he is involuntarily committed to KCPC under Ky. Rev. Stat. 202(C) after being found incompetent to stand trial. See, e.g., O’Bannon v. Dr. Allen, No. 3:22-cv-628-JHM (DN 11); O’Bannon v. K.C.P.C. et al, No. 3:24-cv-573-JHM (DN 5). 2 The Court takes judicial notice that Randy White is actually the commissioner of the Kentucky Department of Juvenile Justice. See https://djj.ky.gov/About%20DJJ/Pages/DJJleadership.aspx (last accessed Feb. 20, 2025). Plaintiff attaches to the complaint documents which he states show that he does not meet the criteria for serious mental illness “as defined by Kentucky Revised statute.” He also asserts that he has “Proof by prior convictions that I have been previously been determined to be competent. I also enclosed a copy of Proof that I have never been evaluated with KCPC doctors.” As relief, Plaintiff seeks damages and release from KCPC.

II. Under § 1915(e)(2)(B), the trial court must review and dismiss the complaint, or any portion of the complaint, if it determines that the complaint is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. To survive dismissal for failure to state a claim, “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) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Court recognizes that pro se pleadings are to be held to a less stringent standard than

formal pleadings drafted by lawyers. Haines v. Kerner, 404 U.S. 519 (1972). The duty to be less stringent with pro se complaints, however, “does not require [the Court] to conjure up unpled allegations,” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979) (citation omitted), and the Court is not required to create a claim for a pro se plaintiff. Clark v. Nat’l Travelers Life Ins. Co., 518 F.2d 1167, 1169 (6th Cir. 1975). To command otherwise would require the “courts to explore exhaustively all potential claims of a pro se plaintiff, [and] would also transform the district court from its legitimate advisory role to the improper role of an advocate seeking out the strongest arguments and most successful strategies for a party.” Beaudett v. City of Hampton, 775 F.2d 1274, 1278 (4th Cir. 1985). III. “Section 1983 creates no substantive rights, but merely provides remedies for deprivations of rights established elsewhere.” Flint ex rel. Flint v. Ky. Dep't of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Two elements are required to state a claim under § 1983. Gomez v. Toledo, 446 U.S. 635 (1980). “[A] plaintiff must allege the violation of a right secured by the Constitution and

laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988). “Absent either element, a section 1983 claim will not lie.” Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). A.Defendant Commonwealth of Kentucky A state is not a “person” subject to suit under § 1983. Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989); Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994). Additionally, the Eleventh Amendment acts as a bar to all claims for relief against the Commonwealth. A state may not be sued in federal court, regardless of the relief sought, unless the state has waived its sovereign immunity under the Eleventh Amendment, or Congress has overridden it. Puerto Rico Aqueduct

& Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139, 144-46 (1993); Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89, 119-24 (1984); Alabama v. Pugh, 438 U.S. 781, 781-82 (l978). In enacting § 1983, Congress did not intend to override the traditional sovereign immunity of the states. Whittington v. Milby, 928 F.2d 188, 193-94 (6th Cir. 1991) (citing Quern v. Jordan, 440 U.S. 332, 341 (l979)). “[T]he Eleventh Amendment is a true jurisdictional bar” to such claims. Russell v. Lundergan-Grimes, 784 F.3d 1037, 1046 (6th Cir. 2015). Thus, the Court will dismiss Plaintiff’s claims against the Commonwealth of Kentucky for failure to state a claim upon which relief may be granted and for seeking monetary damages from a defendant who is immune from such relief. B.Defendant Randy White 1.Official-Capacity Claim As stated above, although Plaintiff indicates that Defendant White is the “KCPC Commissioner,” he is actually the commissioner of the Kentucky Department of Juvenile Justice. However, either way, he is a state official. State officials sued in their official capacities for money

damages are not “persons” subject to suit under § 1983. Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Alabama v. Pugh
438 U.S. 781 (Supreme Court, 1978)
Quern v. Jordan
440 U.S. 332 (Supreme Court, 1979)
Gomez v. Toledo
446 U.S. 635 (Supreme Court, 1980)
Pennhurst State School and Hospital v. Halderman
465 U.S. 89 (Supreme Court, 1984)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Seling v. Young
531 U.S. 250 (Supreme Court, 2001)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Anthony F. McDonald v. Frank A. Hall
610 F.2d 16 (First Circuit, 1979)
Ray Jackson v. Charles Foti, Jr., Etc.
670 F.2d 516 (Fifth Circuit, 1982)
Karen Christy v. James R. Randlett
932 F.2d 502 (Sixth Circuit, 1991)

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Bluebook (online)
O'Bannon v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/obannon-v-commonwealth-of-kentucky-kywd-2025.