Reed v. JFS - Hamilton County PCSA

CourtDistrict Court, S.D. Ohio
DecidedMay 30, 2025
Docket1:25-cv-00266
StatusUnknown

This text of Reed v. JFS - Hamilton County PCSA (Reed v. JFS - Hamilton County PCSA) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reed v. JFS - Hamilton County PCSA, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

TAYLOR REED, Case No. 1:25-cv-266 Plaintiff, Cole, J. Litkovitz, M.J. vs.

JFS-HAMILTON COUNTY PCSA, et al., REPORT AND Defendants RECOMMENDATION

Plaintiff, a resident of Cincinnati, Ohio, has filed a civil complaint against defendants JFS - Hamilton County PCSA, Paul Cohen, IRS - Hamilton County, and HCJC - Hamilton County. By separate Order, plaintiff has been granted leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. This matter is now before the Court for a sua sponte review of the complaint to determine whether the complaint or any portion of it should be dismissed because it is frivolous, 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). Screening of Complaint A. Legal Standard In enacting the original in forma pauperis statute, Congress recognized that a “litigant whose filing fees and court costs are assumed by the public, unlike a paying litigant, lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits.” Denton v. Hernandez, 504 U.S. 25, 31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To prevent such abusive litigation, Congress has authorized federal courts to dismiss an in forma pauperis complaint if they are satisfied that the action is frivolous or malicious. Id.; see also 28 U.S.C. § 1915(e)(2)(B)(i). A complaint may be dismissed as frivolous when the plaintiff cannot make any claim with a rational or arguable basis in fact or law. Neitzke, 490 U.S. at 328-29; see also Lawler v. Marshall, 898 F.2d 1196, 1198 (6th Cir. 1990). An action has no arguable legal basis when the defendant is immune from suit or when plaintiff claims a violation of a legal interest which clearly does not exist. Neitzke, 490 U.S. at 327. An action

has no arguable factual basis when the allegations are delusional or rise to the level of the irrational or “wholly incredible.” Denton, 504 U.S. at 32; Lawler, 898 F.2d at 1199. The Court need not accept as true factual allegations that are “fantastic or delusional” in reviewing a complaint for frivolousness. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (quoting Neitzke, 490 U.S. at 328). Congress also has authorized the sua sponte dismissal of complaints that fail to state a claim upon which relief may be granted. 28 U.S.C. § 1915 (e)(2)(B)(ii). A complaint filed by a pro se plaintiff must be “liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). By the same token, however,

the 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 Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Hill, 630 F.3d at 470-71 (“dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim” under §§ 1915A(b)(1) and 1915(e)(2)(B)(ii)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). The Court must accept all well-

2 pleaded factual allegations as true, but need not “accept as true a legal conclusion couched as a factual allegation.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). Although a complaint need not contain “detailed factual allegations,” it must provide “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S.

at 678 (citing Twombly, 550 U.S. at 555). A pleading that offers “labels and conclusions” or “a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. The complaint must “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Erickson, 551 U.S. at 93 (citations omitted). B. Plaintiff’s Complaint Plaintiff has tendered her complaint on a standard form used by pro se litigants to bring a civil action. Plaintiff checks the “Title 28 U.S.C. § 1331” and “Title 42 United States Code Section 67” boxes as the bases for federal court jurisdiction. (Doc. 1 at PAGEID 2). A handwritten “Statement of Claim” states: For the statement of claim is the manifestation of trouble for the mother and the children. For JFS, planned abuse and neglect on the mother. The mother has not neglected or abused the children. Moreover, HCJC, shown action of unfinished for seeing the positives of the mother with the children. Furthermore, Paul residence is unknown, and the mother is complainting (sic) for parentage allocation of parentage or parental rights and responsibility and parenting times for Ezekiel Reed. Lastly, the IRS liability has stand, yet the disputes are the enthusiasm of Alliance of Hardship. The invisible is the Treaty of Greenville that has the shorest (sic) gathering of opponents. For the Treaty: Perpetuity is bliss for the mother’s live Birth Certificate is the proof of burden or evidence.

(Id. at PAGEID 3). As relief, plaintiff seeks “for all of the 4 children to be home with the mother” and “700,000.00 to 1 million or 1,000,000.00 in financial monetary.” (Id., at PAGEID 4). 3 C. Resolution Plaintiff’s allegations are insufficient to state a claim with an arguable basis in law over which this federal Court has subject matter jurisdiction. As an initial matter, plaintiff fails to state a claim for relief under “42 U.S.C. Section 67.” The Court construes plaintiff’s complaint as alleging a claim under Title 42 U.S.C. Chapter 67,

which codifies the federal Child Abuse Prevention and Treatment Act (“CAPTA”), 42 U.S.C. § 5101 et seq. However, CAPTA does not create rights enforceable under 42 U.S.C. § 1983. Tony L. ex rel. Simpson v. Childers, 71 F.3d 1182, 1189 (6th Cir. 1995). In addition, plaintiff does not have a private right of action under CAPTA. Id.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Metropolitan Life Insurance v. Taylor
481 U.S. 58 (Supreme Court, 1987)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
"Tony" L. ex rel. Simpson v. Childers
71 F.3d 1182 (Sixth Circuit, 1995)

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Reed v. JFS - Hamilton County PCSA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reed-v-jfs-hamilton-county-pcsa-ohsd-2025.