Ronald Treadwell v. Steve Mnuchin

CourtDistrict Court, S.D. Ohio
DecidedOctober 17, 2025
Docket2:21-cv-01028
StatusUnknown

This text of Ronald Treadwell v. Steve Mnuchin (Ronald Treadwell v. Steve Mnuchin) 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
Ronald Treadwell v. Steve Mnuchin, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

RONALD TREADWELL,

Plaintiff, Case No. 2:21-cv-1028 v. Judge Edmund A. Sargus, Jr. Magistrate Judge Elizabeth P. Deavers STEVE MNUCHIN,

Defendant.

OPINION AND ORDER This matter is before the Court on a Report and Recommendation issued by the Magistrate Judge. (ECF No. 5.) After an initial screen of Plaintiff Ronald Treadwell’s Complaint (ECF No. 4) under 28 U.S.C. §§ 1915A and 1915(e)(2), the Magistrate Judge recommended that the Court dismiss Plaintiff’s claim for failure to state a claim upon which relief can be granted. (ECF No. 5, PageID 49–50.) Plaintiff filed an Objection to the Report and Recommendation. (ECF No. 10.) For the reasons stated in this Opinion and Order, the Court OVERRULES Plaintiff’s Objection and ADOPTS and AFFIRMS the Magistrate Judge’s Report and Recommendation. I. Background Plaintiff filed a Complaint against Defendant Steve Mnuchin, former United States Secretary of the Treasury, claiming that the Internal Revenue Service (“IRS”) improperly garnished a $1,200 CARES Act Economic Impact Payment owed to Plaintiff. (ECF No. 4, PageID 39.) He alleges Defendant garnished the payment and sent it to “the county childrens services for the debt that I owe.” (Id.) Plaintiff, who is incarcerated in an Ohio prison, claims that Defendant acted with deliberate indifference to his medical needs as a prisoner during the Covid-19 pandemic in violation of the Eighth Amendment to the United States Constitution by preventing him from receiving the check. (Id.) He does not state whether he is suing Defendant in his official capacity or his personal capacity. (See id.) II. Report and Recommendation The Magistrate Judge concluded that, to the extent plaintiff brings an official capacity claim, the claim is barred under the doctrine of sovereign immunity. (ECF No. 5, PageID 47–48.) To the extent Plaintiff raises a personal capacity claim against Defendant under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) or otherwise, the Magistrate Judge concluded his claim does not fit within the actionable grounds of a Bivens claim and otherwise lacks merit because the government may garnish CARES Act payments for child support obligations. (Id. PageID 48–49 (citing Butler v. CHFS, No. 6:20-234-WOB, 2020 WL 7322717, at *1 (E.D. Ky. Dec. 11, 2020)).) Accordingly, the Magistrate Judge recommended that the Court dismiss Plaintiff’s claim

for failure to state a claim upon which relief can be granted. (Id. PageID 49–50.) She also recommended the Court certify under 28 U.S.C. § 1915(a)(3) that an appeal of any Order adopting the Report and Recommendation would not be taken in good faith. (Id. PageID 50.) III. Subsequent Procedural History The 14-day period for Plaintiff to file an objection to the Report and Recommendation closed without an objection. (ECF No. 6.) Accordingly, the Court adopted and affirmed the Report and Recommendation, entered judgment, and closed the case. (ECF Nos. 6, 7.) Plaintiff then filed a Motion for Leave to File Delayed Objections. (ECF No. 8.) The Court granted the Motion, reopened the case, and vacated the Order adopting and affirming the Report and Recommendation.

(ECF No. 9.) Plaintiff filed an Objection stating that he raises his claim against Defendant in his personal capacity under Bivens. (ECF No. 10, PageID 63–64.) Plaintiff also argued that Defendant was not authorized to divert his CARES Act payment for the purpose of paying a child support obligation. (Id. PageID 64–65.) IV. Legal Standard A litigant who is the subject of an adverse report and recommendation from a magistrate judge is entitled to de novo review of those portions of the report to which proper objections are made. 28 U.S.C. § 636(b)(1); see also Fed. R. Civ. P. 72(b). Upon review, the Court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1). Upon an initial screening of a complaint under 28 U.S.C. § 1915A, the Magistrate Judge may recommend that the Court dismiss a complaint for failure to state a claim upon which relief can be granted under 28 U.S.C. § 1915(e)(2)(B)(2). To state a claim upon which relief may be granted, plaintiffs must satisfy the pleading

requirements set forth in Rule 8(a), which requires a pleading to contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Accordingly, “[t]o survive a motion to dismiss, 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, 677–78 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “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 (clarifying the plausibility standard from Twombly, 550 U.S. at 556). Furthermore, “[a]lthough for the purposes of a motion to dismiss [a court] must take all of the factual allegations in the complaint

as true, ‘[the court is] not bound to accept as true a legal conclusion couched as a factual allegation.’” Id. (quoting Twombly, 550 U.S. at 555) (internal quotations omitted). Courts liberally construe pleadings by pro se litigants, and such pleadings are subject to “‘less stringent standards than formal pleadings drafted by lawyers’ and can only be dismissed for failure to state a claim if it appears ‘beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.’” Estelle v. Gamble, 429 U.S. 97, 106 (1976) (quoting Haines v. Kerner, 404 U.S. 519, 520–21 (1972) (cleaned up)). The Court must “construe the complaint in the light most favorable to the plaintiff [and] accept all well-pleaded factual allegations as true.” Trzebuckowski v. City of Cleveland, 319 F.3d 853, 855 (6th Cir. 2003). V. Analysis The Magistrate Judge correctly concluded that the narrow causes of action against a federal official in his personal capacity authorized under Bivens and its progeny does not extend to the type of factual situation alleged by Plaintiff. In Carlson v. Green, 446 U.S. 14

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kenneth Haggard v. John Stevens
683 F.3d 714 (Sixth Circuit, 2012)
Ziglar v. Abbasi
582 U.S. 120 (Supreme Court, 2017)

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Ronald Treadwell v. Steve Mnuchin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-treadwell-v-steve-mnuchin-ohsd-2025.