SHEELY v. WARNER ROBINS HOUSING AUTHORITY

CourtDistrict Court, M.D. Georgia
DecidedAugust 21, 2025
Docket5:25-cv-00263
StatusUnknown

This text of SHEELY v. WARNER ROBINS HOUSING AUTHORITY (SHEELY v. WARNER ROBINS HOUSING AUTHORITY) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SHEELY v. WARNER ROBINS HOUSING AUTHORITY, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION BRIANCA MICHELLE SHEELY, Plaintiff, v. CIVIL ACTION NO. 5:25-cv-00263-TES WARNER ROBINS HOUSING AUTHORITY, Defendant.

ORDER

In her Recast Complaint [Doc. 5], pro se Plaintiff Brianca Michelle Sheely brings several claims against Defendant Warner Robins Housing Authority in relation to her residence and subsequent eviction from housing owned and operated by Defendant. The Court previously granted Plaintiff’s motion for leave to proceed in forma pauperis, but directed Plaintiff to file a recast complaint to allow the Court to properly screen the filing under 28 U.S.C. § 1915(e). See [Doc. 3]. Plaintiff initially filed a Recast Complaint on July 18, 2025 [Doc. 4], but later filed a superseding Recast Complaint [Doc. 5] that “replaces the previously submitted version due to a misinterpretation noted in public records.” [Doc. 5-2, p. 1]. Taking the most recent Recast Complaint under review, the Court may now screen the pleading according to § 1915(e). FRIVOLITY SCREENING I. Legal Standard

Since Plaintiff is proceeding in forma pauperis, 28 U.S.C. § 1915(e) requires the Court to review her Complaint to determine whether it is frivolous or malicious or fails to state a claim for which relief may be granted.1 28 U.S.C. § 1915(e)(2)(B)(i)–(ii). The proper contours of the term “frivolous,” have been defined by the Supreme Court to

encompass complaints that, despite their factual allegations and legal conclusions, lack an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). These types of complaints are subject to sua sponte dismissal by a district court. Id. at

324 (noting that dismissals under § 1915(e) “are often made sua sponte prior to the issuance of process, so as to spare prospective defendants the inconvenience and expense of answering such complaints[]”).

More specifically, to survive this initial screening, a claim must contain “sufficient factual matter, accepted as true, to state a claim that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Federal Rule of Civil Procedure 12(b)(6) “authorizes a court to dismiss a claim on the basis of a dispositive issue of law.” Neitzke,

490 U.S. at 326 (citing Hishon v. King & Spalding, 467 U.S. 69, 73 (1984)). Such dismissal

1 The Eleventh Circuit has determined that “28 U.S.C. § 1915(e), which governs proceedings in forma pauperis generally . . . permits district courts to dismiss a case ‘at any time’ if the complaint ‘fails to state a claim on which relief may be granted.’” Robinson v. United States, 484 F. App’x 421, 422 n.2 (11th Cir. 2012) (per curiam); see also 28 U.S.C. § 1915(e)(2)(B)(ii). procedure—operating on the assumption that the factual allegations in the complaint are true—streamlines litigation by dispensing with unnecessary discovery and factfinding. Id. “Nothing in Rule 12(b)(6) confines its sweep to claims of law which are

obviously unsupportable.” Id. at 327. To the contrary, if it is clear, as a matter of law, that no relief could be granted under “any set of facts that could be proven with the allegations,” a claim must be dismissed. Id. (quoting Hishon, 467 U.S. at 73). Frivolity review under § 1915(e), on the other hand, has a separate function.

Section 1915(e) is designed to discourage the filing of—and waste of judicial and private resources upon—baseless lawsuits that paying litigants generally do not initiate due to filing costs and the potential threat of sanctions associated with filing such a lawsuit. Id.

“To this end, the statute accords judges not only the authority to dismiss a claim based on an indisputably meritless legal theory, but also the unusual power to pierce the veil of [a] complaint’s factual allegations and dismiss those claims whose factual contentions

are clearly baseless.” Id. Even though Rule 12 and § 1915(e) both counsel dismissal and share “considerable common ground” with each other, one dismissal standard does not invariably encompass the other. Id. at 328. “When a complaint raises an arguable question of law which the district court ultimately finds is correctly resolved against [a]

plaintiff, dismissal on Rule 12(b)(6) grounds is appropriate, but dismissal on the basis of frivolousness is not.” Id. II. Plaintiff’s Complaint Plaintiff’s allegations stem from her time as a resident that the Defendant owned and operated. Plaintiff primarily alleges that Defendant violated her right to privacy

under 42 U.S.C. § 1983 and O.C.G.A. § 44-7-33, breached housing standards under 24 C.F.R. § 982.401 and O.C.G.A. § 44-7-13, retaliated against Plaintiff under the Fair Housing Act, and suffering from intentional infliction of emotional distress as a result of Defendant’s actions. [Doc. 5, p. 3]. According to Plaintiff’s Recast Complaint, Plaintiff

lived as a tenant in a property owned and operated by Defendant. [Doc. 5, p. 1]. Plaintiff alleges that during her tenancy, Defendant’s staff entered her residence “on multiple occasions without providing the mandatory 24-hour written notice, in

violation of O.C.G.A. § 44-7-33(b) and federal housing regulations.” [Id.]. Plaintiff furthermore alleges multiple unsafe and uninhabitable living conditions and that Plaintiff had been displaced from her residence without notice, hearing, or explanation.

[Doc. 5, p. 2]. Plaintiff, however, once again fails to allege sufficient facts for the claims she seeks to bring before the Court. As explained in the Court’s previous Order [Doc. 3], “[u]nder the Fair Housing Act, it is unlawful ‘[t]o discriminate against any person in the terms,

conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin.’ 42 U.S.C. § 3604(b).” [Doc. 3, p. 5]. As written, Plaintiff’s Recast Complaint fails to support a claim under the Fair Housing Act. Plaintiff again fails to allege discrimination of any kind. As such, Plaintiff’s claim under the Fair Housing Act does not pass muster and must be dismissed by the Court.

Furthermore, Plaintiff’s claim under 42 U.S.C. § 1983 is likewise insufficient.

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Related

Epps v. Watson
492 F.3d 1240 (Eleventh Circuit, 2007)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Hishon v. King & Spalding
467 U.S. 69 (Supreme Court, 1984)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Donald Robinson v. United States
484 F. App'x 421 (Eleventh Circuit, 2012)

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SHEELY v. WARNER ROBINS HOUSING AUTHORITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheely-v-warner-robins-housing-authority-gamd-2025.