O'Bannon v. McMahon

CourtDistrict Court, W.D. Kentucky
DecidedOctober 2, 2025
Docket3:25-cv-00468
StatusUnknown

This text of O'Bannon v. McMahon (O'Bannon v. McMahon) 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. McMahon, (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-00468-JHM

BETH MCMAHON, et al. DEFENDANTS

MEMORANDUM OPINION Plaintiff Antonio Lee O’Bannon, proceeding pro se, initiated this 42 U.S.C. § 1983 action. The complaint is before the Court for screening pursuant to 28 U.S.C. § 1915(e)(2) and McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). For the following reasons, this action will be dismissed. I. SUMMARY OF FACTUAL ALLEGATIONS Plaintiff is housed at the Kentucky Correctional Psychiatric Center (KCPC).1 He sues the Department of Public Advocacy (DPA), as well as DPA attorney Beth McMahon, guardian ad litem Chad Graham, and Louisville Metro Public Defender2 attorney Sheila Seadler in their individual capacities. Plaintiff alleges that between October 3, 2023, and July 14, 2025, Defendants McMahon and Seadler “allow[ed] the Jefferson County Circuit Courts and K.C.P.C. to force me medication with no mental health history, from a outside mental health hospital. And no prior history of involuntary hospitalizations under KRS Chapter 202A or 202B.” He further alleges that between September 2023, and July 14, 2025, Defendants McMahon and Seadler “allow[ed] the Jefferson

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. § 202C 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 Effective July 1, 2024, the DPA assumed administration of indigent defense services formerly provided by the Louisville—Jefferson County Public Defender Corporation. See Ky. Rev. Stat. § 31.030 (2024); 2023 KY H.B. 568. County Circuit to unlawfully imprison me in K.C.P.C. under a law called the 202C involuntary commitment for over two years.” Plaintiff states that these Defendants “are not representing me to the best of the ability[,]” and “did nothing to help me[,]” and indicates that he filed a complaint against McMahon and Seadler to the Bar Association on October 23, 2023. Plaintiff also alleges that on December 17, 2024, while in the court’s “attorney booth,”

Seadler called him a racial slur and said that he “deserve[d] everything that’s happening” to him. Finally, Plaintiff alleges that McMahon, Seadler, and Graham “did not fight for me on the force treatment of medication order,” that he is “not satisfied with there representation.” As relief, Plaintiff seeks monetary damages and “release from K.C.P.C. or grant new representation.” II. STANDARD Because Plaintiff is proceeding in forma pauperis, this Court must review the instant action. 28 U.S.C. § 1915(e); McGore, 114 F.3d at 608-09. Upon review, the Court must dismiss a case at any time if it determines that an action 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. See 28 U.S.C. § 1915(e)(2)(B). This 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); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991). However, the duty “does not require us to conjure up unpled allegations.” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979). In order 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)). “[A] district court must (1) view the complaint in the light most favorable to the plaintiff and (2) take all well-pleaded factual allegations as true.” Tackett v. M & G Polymers, USA, LLC, 561 F.3d 478, 488 (6th Cir. 2009) (citing Gunasekera v. Irwin, 551 F.3d 461, 466 (6th Cir. 2009) (citations omitted)). “But the district court need not accept a ‘bare assertion of legal conclusions.’” Tackett, 561 F.3d at 488 (quoting Columbia Natural Res., Inc. v. Tatum, 58 F.3d

1101, 1109 (6th Cir. 1995)). III. ANALYSIS Section 1983 creates a cause of action against any person who, under color of state law, causes the deprivation of a right secured by the Constitution or the laws of the United States. A claim under § 1983 must therefore allege two elements: (1) the deprivation of federal statutory or constitutional rights by (2) a person acting under color of state law. West v. Atkins, 487 U.S. 42, 48 (1988); Flint v. Ky. Dep’t of Corr., 270 F.3d 340, 351 (6th Cir. 2001). Absent either element, no § 1983 claim exists. Christy v. Randlett, 932 F.2d 502, 504 (6th Cir. 1991). A. Attorney Defendants

Plaintiff sues McMahon and Seadler, his public defenders. It is well-settled that a defense attorney, regardless of whether he is a public defender or a private attorney, is not a state actor for purposes of § 1983. Polk Cnty. v. Dodson, 454 U.S. 312, 325 (1981) (“[A] public defender does not act under color of state law when performing a lawyer’s traditional functions as counsel to a defendant in a criminal proceeding.”); Otworth v. Vanderploeg, 61 F. App’x 163, 165 (6th Cir. 2003) (“[A] lawyer representing a client is not, by virtue of being an officer of the court, a state actor under color of state law within the meaning of § 1983.”). Thus, Plaintiff’s claim against McMahon and Seadler stemming from their roles as criminal defense counsel must be dismissed for failure to state a claim upon which relief may be granted. B. Guardian Ad Litem Plaintiff’s claim against Defendant Graham is also subject to dismissal. Graham, who is presumably Plaintiff’s court-appointed guardian ad litem (GAL) in his criminal proceedings, is not a state actor for purposes of § 1983. See, e.g., McClear v. Donaldson, 812 F.2d 1407 (6th Cir. 1987) (table) (explaining that the GAL’s “actions in the state proceedings were done in fulfillment

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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)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (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)
Karen Christy v. James R. Randlett
932 F.2d 502 (Sixth Circuit, 1991)
James M. Jourdan, Jr. v. John Jabe and L. Boyd
951 F.2d 108 (Sixth Circuit, 1991)
Tackett v. M & G POLYMERS, USA, LLC
561 F.3d 478 (Sixth Circuit, 2009)
Gunasekera v. Irwin
551 F.3d 461 (Sixth Circuit, 2009)
Holley v. Deal
948 F. Supp. 711 (M.D. Tennessee, 1996)
Otworth v. Vanderploeg
61 F. App'x 163 (Sixth Circuit, 2003)

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Bluebook (online)
O'Bannon v. McMahon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/obannon-v-mcmahon-kywd-2025.