Robert Bowen v. Hamilton County Sheriff’s Office and Hamilton County Jail and Detention Center

CourtDistrict Court, E.D. Tennessee
DecidedMarch 3, 2026
Docket1:26-cv-00053
StatusUnknown

This text of Robert Bowen v. Hamilton County Sheriff’s Office and Hamilton County Jail and Detention Center (Robert Bowen v. Hamilton County Sheriff’s Office and Hamilton County Jail and Detention Center) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Bowen v. Hamilton County Sheriff’s Office and Hamilton County Jail and Detention Center, (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

ROBERT BOWEN, ) ) Case No. 1:26-cv-53 Plaintiff, ) ) Judge Atchley v. ) ) Magistrate Judge Steger HAMILTON COUNTY SHERIFF’S ) OFFICE and HAMILTON COUNTY JAIL ) AND DETENTION CENTER, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Plaintiff Robert Bowen, a prisoner housed in the Hamilton County Jail and Detention Center (“Jail”) has filed a letter to the Clerk, which was docketed as a civil rights complaint [Doc. 1] and a motion for leave to proceed in forma pauperis [Doc. 4]. For the reasons set forth below, the Court will GRANT Plaintiff’s motion to proceed in forma pauperis [Doc. 4], DISMISS the current Defendants, and PERMIT Plaintiff to file an amended complaint. I. MOTION TO PROCEED IN FORMA PAUPERIS Under the Prison Litigation Reform Act (“PLRA”), a prisoner bringing a civil action may apply for permission to file suit without prepaying the filing fee. See 28 U.S.C. § 1915(a). A review of Plaintiff’s motion demonstrates that he lacks sufficient financial resources to pay the filing fee in a lump sum. Accordingly, pursuant to 28 U.S.C. § 1915, the Court will GRANT this motion [Doc. 4]. The Court will ASSESS Plaintiff the civil filing fee of $350.00 and DIRECT the custodian of Plaintiff’s inmate trust account to submit to the Clerk, U.S. District Court, 900 Georgia Avenue, Suite 309, Chattanooga, Tennessee, 37402 twenty percent (20%) of Plaintiff’s preceding monthly income (or income credited to Plaintiff’s trust account for the preceding month), but only when such monthly income exceeds ten dollars ($10.00), until the full filing fee of three hundred fifty dollars ($350.00) as authorized under 28 U.S.C. § 1914(a) has been paid to the Clerk. 28 U.S.C. § 1915(b)(2). The Court will DIRECT the Clerk to send a copy of this Order to the Court’s financial deputy and the custodian of inmate trust accounts at Plaintiff’s current facility to ensure

compliance with the PLRA’s requirements for payment of the filing fee. II. SCREENING OF COMPLAINT A. Standard Under the PLRA, district courts must screen prisoner complaints and sua sponte dismiss any claims that are “frivolous, malicious, or fail[] to state a claim upon which relief may be granted,” or “seek[] monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b); see also 28 U.S.C. § 1915(e)(2)(B); Benson v. O’Brian, 179 F.3d 1014 (6th Cir. 1999). The dismissal standard articulated by the Supreme Court in Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) “governs dismissals for failure to state a

claim under [28 U.S.C. §§ 1915(e)(2)(B) and 1915A] because the relevant statutory language tracks the language in Rule 12(b)(6)” of the Federal Rules of Civil Procedure. Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (citations omitted). Thus, to survive an initial review under the PLRA, a complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). B. Analysis1 First, Plaintiff identifies the Hamilton County Sheriff’s Office and the Jail as possible Defendants. [See generally Doc. 1]. But neither a Sheriff’s Office nor a Jail are entities that are subject to suit under 42 U.S.C. § 1983. See Anciani v. Davidson Cnty. Sheriff Office, No. 3:19-cv- 169, 2019 WL 1002503, at *2 (M.D. Tenn. Feb. 28, 2019) (“It is well established that in Tennessee

federal courts, a sheriff’s office or police department is not a ‘person’ subject to suit under 42 U.S.C. §1983”)(citing Matthews v. Jones, 35 F.3d 1046, 1049 (6th Cir. 1994)); Cage v. Kent County Corr. Facility, No. 96-1167, 1997 WL 225647, at *1 (6th Cir. May 1, 1997) (stating that “[t]he district court also properly found that the jail facility named as a defendant was not an entity subject to suit under § 1983”). Therefore, the Court will dismiss Defendants. Second, Plaintiff asks the Court to “send [him] some information relating to [his] questions” about (1) his friend’s desire to pursue charges against officers for excessive force and the destruction of property; (2) the delay Plaintiff has faced in going to trial; (3) the possibility of a case against the Hamilton County District Attorney for the use of officers to deny Plaintiff his

freedom of speech; (4) any claim against Plaintiff’s arresting officers for excessive force; and (5) a possible case against the Jail related to the conditions of confinement. [See generally Doc. 1]. However, Plaintiff cannot raise his friend’s legal issues in this action. Newsom v. Norris, 888 F.2d 371, 381 (6th Cir. 1989) (holding that a “a prisoner . . . is limited to asserting alleged violations of

1 As noted above, Plaintiff did not file a document captioned as a “complaint.” [See generally Doc. 1]. But after Plaintiff filed his letter to the Clerk, the Clerk mailed him a Notice advising him that the Court was in receipt of his complaint and that he must remit the filing fee or submit a motion to proceed in forma pauperis if he wanted this case to proceed. [Doc. 2]. Thereafter, Plaintiff filed a motion for leave to proceed in forma pauperis and accompanying documents, thus indicating his desire to pursue this litigation. [Doc. 4]. Accordingly, the Court construes Plaintiff’s letter as a civil rights complaint under 42 U.S.C. § 1983. See FED. R. CIV. P. 3 (providing that “[a] civil action is commenced by filing a complaint with the Court.”). his own constitutional rights and . . . lacks standing to assert the constitutional rights of other prisoners”). And as to Plaintiff’s remaining allegations, it appears that Plaintiff seeks to raise unrelated claims against different defendants, which he must do in separate § 1983 actions.2 While a plaintiff may join as many claims as he has against an opposing party under Rule 18(a) of the Federal Rules of Civil Procedure, Rule 20(a)(2) allows a plaintiff to sue multiple

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Related

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)
Geoffrey Benson v. Greg O'Brian
179 F.3d 1014 (Sixth Circuit, 1999)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Proctor v. Applegate
661 F. Supp. 2d 743 (E.D. Michigan, 2009)

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Robert Bowen v. Hamilton County Sheriff’s Office and Hamilton County Jail and Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-bowen-v-hamilton-county-sheriffs-office-and-hamilton-county-jail-tned-2026.