Shull v. Earnhart

CourtDistrict Court, N.D. Indiana
DecidedMay 16, 2025
Docket1:25-cv-00085
StatusUnknown

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

Bluebook
Shull v. Earnhart, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

JONATHON P. SHULL,

Plaintiff,

v. CAUSE NO. 1:25-CV-85-JD-AZ

AMBER EARNHART, et al.,

Defendants.

OPINION AND ORDER Jonathon P. Shull, a prisoner without a lawyer, filed an amended complaint. ECF 11. “A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted). Nevertheless, under 28 U.S.C. § 1915A, the court must review the merits of a prisoner complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. In the amended complaint, Shull asserts due process violations and State law claims against five defendants in connection with his efforts to litigate his State criminal case. The court has identified this case as State v. Shull, 27D02-1912-F4-47 (Grant Sup. Ct. filed Dec. 13, 2019).1 Though the complaint is light on detail, his principal claims appear

1 Pursuant to Fed. R. Evid. 201, the court takes judicial notice of the electronic dockets for the Indiana courts, which are available at https://public.courts.in.gov/mycase/. to be against the clerk’s office for the Grant Superior Court and the administrative clerk, Amber Earnhart, who signed for the receipt of his petition relating to interstate detainer

by mail when Shull was incarcerated in Kentucky. The signed receipt slip attached to the amended complaint is dated October 31, 2020. From the exhibits and Shull’s written descriptions of them, it appears that he submitted a “Petition for Dismissal of Charges” to the Grant Superior Court on October 16, 2022, and again on January 18, 2023, and he alleges that those petitions also went undocketed.2 However, the State court docket reflects that a “Petition for Dismissal of Charges” was filed on January 23, 2023,

The applicable statute of limitations requires plaintiffs to file lawsuits within two years of the date on which the injury occurred. Behavioral Inst. of Ind., LLC v. Hobart City of Common Council, 406 F.3d 926, 929 (7th Cir. 2005). As a result, the limitations period for the last undocketed petition expired in October 2024. Shull did not file the initial complaint in this case until February 18, 2025 (ECF 1 at 4), so the claims against Clerk

Earnhart and the clerk’s office for the Grant Superior Court for failing to docket his motions are untimely. Shull asserts claims against Judge Foust for not setting court dates to resolve the undocketed motions. He also asserts claims against Prosecutor Scott for not setting court dates and for not docketing his motions. It seems unlikely that a judge has the

duty to set court dates to resolve motions without ever receiving notice of those

2 Shull also alleges that motions for leave to proceed in forma pauperis went undocketed, but it does not appear that his in forma pauperis status was ever in question or that he suffered any harm as a result of these undocketed motions. motions or that a prosecutor has the duty or ability to docket motions filed by opposing parties or to set court dates. Even if they did, such claims would be barred by judicial

and prosecutorial immunity. See Fields v. Wharrie, 672 F.3d 505, 510 (7th Cir. 2012) (“A prosecutor is absolutely immune from suit for all actions and decisions undertaken in furtherance of his prosecutorial duties.”); Polzin v. Gage, 636 F.3d 834, 838 (7th Cir. 2011) (“A judge has absolute immunity for any judicial actions unless the judge acted in absence of all jurisdiction.”). Shull asserts that Attorney Eib, his public defender, violated his constitutional

rights for not responding to Shull or his mother, not filing motions, and not complying with instructions not to allow continuances. “[A] public defender does not act under color of state law when performing a lawyer’s traditional functions as counsel to a defendant in a criminal proceeding.” Polk Cnty. v. Dodson, 454 U.S. 312, 325 (1981). Because Attorney Eid was not a State actor, Shull may not proceed against him on a

constitutional claim. He also asserts State law claims against Attorney Eib, including negligence and negligent infliction of emotional distress. Because the amended complaint does not plausibly state any federal claims, Shull may only proceed against Attorney Eib on State law claims if the elements of diversity jurisdiction are satisfied. See 28 U.S.C. § 1331

(federal question jurisdiction); 28 U.S.C. § 1332 (diversity jurisdiction); 28 U.S.C. § 1367 (supplemental jurisdiction). Diversity jurisdiction requires a diversity of State citizenship among the parties, but the amended complaint indicates that Shull and Attorney Eib both reside in Indiana and are thus citizens of Indiana. As a result, it appears that the court lacks subject matter jurisdiction over these claims.

Additionally, Shull has not plausibly stated any State law claims against Attorney Eib. With respect to negligent infliction of emotional distress, the Indiana Supreme Court has articulated the following: The right to seek damages for emotional distress in actions for negligence often referred to as actions for negligent infliction of emotional distress, is carefully circumscribed under Indiana jurisprudence. We have never permitted, nor do we today, an action seeking damages for emotional distress predicated upon a breach of an alleged duty not to inflict emotional injury on another. Such independent, stand-alone actions for negligent infliction of emotional distress are not cognizable in Indiana. But actions seeking damages for emotional distress resulting from the negligence of another are permitted in two situations: where the plaintiff has (1) witnessed or come to the scene soon thereafter the death or severe injury of certain classes of relatives (i.e., the bystander rule) or (2) suffered a direct impact (i.e., the modified impact rule).

Spangler v. Bechtel, 958 N.E.2d 458, 466 (Ind. 2011). “The modified impact rule maintains the requirement of a direct physical impact.” Conder v. Wood, 716 N.E.2d 432, 434 (Ind. 1999) (cited with approval in K.G. by Next Friend Ruch v. Smith, 178 N.E.3d 300, 306 (Ind. 2021)). “However, the impact need not cause a physical injury to the plaintiff and the emotional trauma suffered by the plaintiff need not result from a physical injury caused by the impact.” Id. There are no allegations that Shull was present during the death or injury of a relative or that Attorney Eib’s alleged misconduct had any physical impact on Shull.

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Related

Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Polzin v. Gage
636 F.3d 834 (Seventh Circuit, 2011)
Nathson Fields v. Lawrence Wharrie
672 F.3d 505 (Seventh Circuit, 2012)
Spangler v. Bechtel
958 N.E.2d 458 (Indiana Supreme Court, 2011)
Conder v. Wood
716 N.E.2d 432 (Indiana Supreme Court, 1999)
Mhammad Abu-Shawish v. United States
898 F.3d 726 (Seventh Circuit, 2018)

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Bluebook (online)
Shull v. Earnhart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shull-v-earnhart-innd-2025.