Richmond v. Bullock

CourtDistrict Court, E.D. Missouri
DecidedAugust 5, 2025
Docket4:25-cv-00367
StatusUnknown

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

Bluebook
Richmond v. Bullock, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

TYRON RICHMOND, ) ) Plaintiff, ) ) v. ) Case No. 4:25-cv-00367-JSD ) CASI BULLOCK, et al., ) ) Defendants. )

MEMORANDUM AND ORDER

Self-represented Plaintiff Tyron Richmond is a state-prisoner confined at the Eastern Reception, Diagnostic and Correctional Center (ERDCC) in Bonne Terre, Missouri. He brings this 42 U.S.C. § 1983 civil rights action against three employees at ERDCC. The matter is now before the Court upon Plaintiff’s motion for leave to proceed in forma pauperis, or without prepayment of the required filing fees and costs. ECF No. 2. As explained in detail below, the motion will be granted, and the surplus amount that Plaintiff overpaid will be returned to him. Furthermore, because Plaintiff is now proceeding in forma pauperis, his Complaint is subject to review under 28 U.S.C. § 1915. Based on such review, the Court will dismiss this case for failure to state a claim upon which relief may be granted. See 28 U.S.C. § 1915(e)(2)(B). As such, Plaintiff’s motion for appointment of counsel will be denied as moot. Motion to Proceed In Forma Pauperis Pursuant to 28 U.S.C. § 1915(b)(1), a prisoner bringing a civil action in forma pauperis is required to pay the full amount of the filing fee. If the prisoner has insufficient funds in his or her prison account to pay the entire fee, the Court must assess and, when funds exist, collect an initial partial filing fee of 20 percent of the greater of (1)

the average monthly deposits in the prisoner’s account, or (2) the average monthly balance in the prisoner’s account for the prior six-month period. After payment of the initial partial filing fee, the prisoner is required to make monthly payments of 20 percent of the preceding month’s income credited to the prisoner’s account. 28 U.S.C. § 1915(b)(2). The agency having custody of the prisoner will forward these monthly payments to the Clerk of Court each time the amount in the prisoner’s account exceeds

$10, until the filing fee is fully paid. Id. In this case, Plaintiff filed his complaint on March 21, 2025, along with his motion to proceed in forma pauperis. ECF Nos. 1-2. Approximately six weeks later, Plaintiff filed an inmate account statement and paid the full filing fee amount of $405. ECF Nos. 4-5. Over two months have passed since the filing fee was paid in full and Plaintiff has

not withdrawn his motion to proceed in forma pauperis. Because in forma pauperis status confers benefits on litigants aside from payment of the filing fee in installments and because Plaintiff has not withdrawn his motion, the Court will assume that Plaintiff still seeks such status in this case. After review of the financial information submitted in support of the motion, the Court will grant Plaintiffs’ motion to proceed in forma

pauperis. Plaintiff could now avail himself of the other benefits of in forma pauperis status, such as reduced copy rates and service on defendants by the U.S. Marshal’s Service. The Court will direct the Clerk to refund Plaintiff the surplus administrative fee.1

Legal Standard on Initial Review Under 28 U.S.C. § 1915(e)(2), the Court may dismiss a complaint filed in forma pauperis if the action is frivolous or malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief against a defendant who is immune from such relief. When reviewing a complaint filed by a self-represented person under 28 U.S.C. § 1915, the Court accepts the well-pleaded facts as true, White v. Clark, 750 F.2d 721, 722 (8th

Cir. 1984), and it liberally construes the complaint. Erickson v. Pardus, 551 U.S. 89, 94 (2007); Haines v. Kerner, 404 U.S. 519, 520 (1972). A “liberal construction” means that if the essence of an allegation is discernible, the district court should construe the plaintiff’s complaint in a way that permits the claim to be considered within the proper legal framework. Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015). However, even

self-represented plaintiffs are required to allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980); see also

1 The Court’s filing fee for bringing a civil action (filed after December 1, 2023) is $405, which includes a statutory filing fee of $350 and an administrative fee of $55. See 28 U.S.C. § 1914(a) (“The clerk of each district court shall require the parties instituting any civil action, suit or proceeding in such court, whether by original process, removal, or otherwise, to pay a filing fee of $350”); 28 U.S.C. § 1914(b) (“The clerk shall collect from the parties such additional fees only as are prescribed by the Judicial Conference of the United States”); Par. 14 of the Judicial Conference Schedule of Fees, District Court Miscellaneous Fee Schedule (issued in accordance with 28 U.S.C. § 1914) (effective on Dec. 1, 2023) ($55.00 administrative fee added to the statutory fee for filing a civil action in district court).

However, the Judicial Conference expressly provided that the additional $55.00 “fee does not apply to applications for a writ of habeas corpus or to persons granted in forma pauperis status under 28 U.S.C. § 1915.” Id. Since Plaintiff is now proceeding in forma pauperis, the Court will direct that the $55 administrative fee be returned to him. Stone v. Harry, 364 F.3d 912, 914-15 (8th Cir. 2004) (refusing to supply additional facts or to construct a legal theory for the self-represented plaintiff).

To state a claim for relief, a complaint must plead more than “legal conclusions” and “[t]hreadbare recitals of the elements of a cause of action [that are] supported by mere conclusory statements.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A plaintiff must demonstrate a plausible claim for relief, which is more than a “mere possibility of misconduct.” Id. at 679. “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.” Id. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw on its judicial experience and common sense. Id. at 679. The Complaint Plaintiff Tyron Richmond, an inmate at ERDCC, initiated this 42 U.S.C.

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Richmond v. Bullock, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richmond-v-bullock-moed-2025.