Sanford v. Elder

CourtDistrict Court, D. Oregon
DecidedJanuary 30, 2025
Docket1:24-cv-01671
StatusUnknown

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

Bluebook
Sanford v. Elder, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

MEDFORD DIVISION

SEAN C. SANFORD, Civ. No. 1:24-cv-01671-AA

Plaintiff, OPINION & ORDER v.

KILE CLARK ELDER, Defendant. _______________________________________

AIKEN, District Judge.

Pro Se Plaintiff Sean C. Sanford seeks leave to proceed in forma pauperis (“IFP”) in this action. For the reasons set forth below, Plaintiff’s IFP Petition, ECF No. 2, is GRANTED but Plaintiff’s Complaint, ECF No. 1, is DISMISSED with leave to amend but without service on Defendant. LEGAL STANDARD Generally, all parties instituting any civil action in United States District Court must pay a statutory filing fee. 28 U.S.C. § 1914(a). However, the federal IFP statute, 28 U.S.C. § 1915(a)(1), provides indigent litigants an opportunity for meaningful access to federal courts despite their inability to pay the costs and fees associated with that access. To authorize a litigant to proceed IFP, a court must make two determinations. First, a court must determine whether the litigant is unable to pay the costs of commencing the action. 28 U.S.C. § 1915(a)(1). Second, it must assess whether the action is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune to such relief. 28 U.S.C. § 1915(e)(2)(B).

With regard to the second of these determinations, district courts have the power under 28 U.S.C. § 1915(e)(2)(B) to screen complaints even before service of the complaint on the defendants and must dismiss a complaint if it fails to state a claim. Courts apply the same standard under 28 U.S.C. § 1915(e)(2)(B) as when addressing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). Watison v. Carter, 668 F.3d 1108, 1112 (9th Cir. 2012). To survive a motion to dismiss under the federal

pleading standards, the complaint must include a short and plain statement of the claim and “contain sufficient factual matter, accepted as true, to ‘state a claim for 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 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. The plausibility standard . . . asks for more than a sheer possibility that a defendant has acted

unlawfully.” Id. The court is not required to accept legal conclusions, unsupported by alleged facts, as true. Id. Pro se pleadings are held to less stringent standards than pleadings by attorneys. Haines v. Kerner, 404 U.S. 519, 520-21 (1972). That is, the court should construe pleadings by pro se plaintiffs liberally and afford the plaintiffs the benefit of any doubt. Karim-Panahi v. Los Angeles Police Dep’t, 839 F.2d 621, 623 (9th Cir. 1988). Additionally, a pro se litigant is entitled to notice of the deficiencies in the complaint and the opportunity to amend, unless the complaint’s deficiencies cannot be cured by amendment. Id.

DISCUSSION When assessing an IFP petition, the Court first must determine whether the plaintiff has made a sufficient showing of indigency. Here, the Court is satisfied by Plaintiff’s showing and so Plaintiff’s IFP Petition is GRANTED. I. Plaintiff’s Claims With regard to the substance of the Complaint, Plaintiff asserts that the basis

for jurisdiction is a federal question under 18 U.S.C. §§ 35, 242, 1038, 3283. Compl. at 3, ECF No. 1. Plaintiff claims that the nature of his suit arises under the False Claims Act; a question of constitutionality of state statutes; and other civil rights. Id. at 8. Plaintiff states that in July 2023, Defendant “Kyle Clark Elder created, printed, laminated, and distributed an illicit, and unauthorized [poster] about Plaintiff. Id. at 4. The poster is attached to Plaintiff’s Complaint, and indeed is alarming. It states, “wanted-dead or alive” and features a photo that arguably depicts Plaintiff,

claiming that Plaintiff is engaged in sexual crimes against minors. ECF No. 1-1. II. Pleadings On the alleged facts, the Court is unable to make out a claim. It appears to the Court that Plaintiff is asserting that Defendant has made false claims about him and that this wronged Plaintiff. But the statutes Plaintiff cites to under Title 18 are criminal statutes. Criminal statutes are not enforceable by private parties in a civil action. Courts have held that private parties generally do not have standing to compel the prosecution of another person. See Tia v. Criminal Investigation Demanded as Set Forth, 441 Fed. App’x 457, 458 (9th Cir. 2011) (holding that a

private citizen “lacks standing to compel an investigation or prosecution of another person.”). If Plaintiff intends to compel an investigation or prosecution, he lacks standing. Further, in Plaintiff’s pleadings, the Court cannot not find a state statute, the constitutionality of which is at issue. Plaintiff has also not pled a claim under the False Claims Act, 31 U.S.C. § 3729, which imposes penalties on people who knowingly

defraud the federal government by submitting a false claim for payment. The Court can also not discern a civil right at issue. The Complaint falls below the federal pleading standards and will be dismissed for failure to state a claim. III. Jurisdiction Plaintiff states that Defendant is from Oregon. Given that both Plaintiff and Defendant are allegedly citizens of the same state, Diversity Jurisdiction does not apply. 28 U.S.C. § 1332. Plaintiff alleges that the Court has federal jurisdiction

based on the presence of a federal question of law in his case. Compl. at 3. Federal courts may exercise federal-question jurisdiction over an action in two situations. First, and most commonly, a federal court may exercise federal-question jurisdiction if a federal right or immunity is “an element, and an essential one, of the plaintiff's cause of action.’” Franchise Tax Bd. v. Constr. Laborers Vacation Trust for S. Cal., 463 U.S. 1, 11 (1983). Second, a federal court may have federal question jurisdiction if a state-law claim “necessarily raise[s] a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally-approved balance of federal and state judicial responsibilities.”

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Sanford v. Elder, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanford-v-elder-ord-2025.