Smith v. Humphrey

CourtDistrict Court, D. Nebraska
DecidedMay 29, 2025
Docket8:24-cv-00271
StatusUnknown

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

Bluebook
Smith v. Humphrey, (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

EDWARD J. SMITH,

Plaintiff, 8:24CV271

vs. ORDER ELIZABETH HUMPHREY, and JOSEPH HENDRICKS,

Defendants.

Pro se plaintiff, Edward Smith alleges the Elizabeth Humphrey and Joseph Hendricks conspired to falsify evidence in state court proceedings—forcing the sale of his property. These allegations trigger Fed. R. Civ. P. 9(b), which requires fraud to be pled with particularity. Because Smith does not, his complaint does not survive initial review. But Smith may file an amended complaint setting out the what and the how of the alleged fraud. SUMMARY OF THE COMPLAINT Smith’s complaint alleges Humphrey and Hendricks (both Texas residents) “conspired with Elizabeth’s mother . . . to knowingly and intentionally commit a criminal act of preparing and presenting false evidence with the results ending with the fraudulent” theft of Smith’s real estate property. Filing No. 1 at 5. Specifically, Defendants “prepared false evidence in an Affidavit for Transfer of Real Property without Probate and a Complaint for Partition to force the [sale]” of Smith’s property. Id. In connection with the scheme, Humphrey “forged an Amortization Schedule on October 5, 2018, which was used as a legal document and the basis and foundation to misrepresent facts and fabricate evidence in a Complaint for Partition.” Id. at 7. Additionally, Defendants “willingly and deliberately prepar[ed] and submit[ed] tampered physical evidence” at a state court trial on April 10, 2023, and “willingly fil[ed] false facts on an Affidavit for Transfer of Real Property without Probate.” Id. Smith does not identify what false statements Defendants made in these documents, what portions were fabricated, or how the false statements led to the sale of his property. “[T]he agreement between the criminal conspirators worked

and without holding any interest in the Plaintiff real estate property on May 28, 2024,” Smith lost “his property and it now awaiting the unlawful referee’s” sale “of the property.” Id. at 5. Because of this conspiracy, Smith suffered financial losses valued at $390,000. Id. at 4. STANDARDS ON INITIAL REVIEW The Court is required to review in forma pauperis complaints to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). The Court must dismiss a complaint or any portion of it that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant

who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). Pro se plaintiffs must set forth enough factual allegations to “nudge[] their claims across the line from conceivable to plausible,” or “their complaint must be dismissed.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 569–70 (2007); see also Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (“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.”). Fed. R. Civ. P. 9(b) provides “[i]n alleging fraud . . ., a party must state with particularity the circumstances constituting fraud . . ..” But “[m]alice, intent, knowledge, and other conditions of a person’s mind may be alleged generally.” Fed. R. Civ. P. 9(b). The particularity requirement “deters the use of complaints as a pretext for fishing expeditions of unknown wrongs designed to compel in terrorem settlements,” “protects against damage to professional reputations resulting from allegations of moral turpitude,” and “ensures that a defendant is given sufficient notice of the allegations against him to permit the preparation of an effective defense.” Parnes v. Gateway 2000,

Inc., 122 F.3d 539, 549 (8th Cir. 1997). “The essential function of a complaint under the Federal Rules of Civil Procedure is to give the opposing party ‘fair notice of the nature and basis or grounds for a claim, and a general indication of the type of litigation involved.’” Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 848 (8th Cir. 2014) (quoting Hopkins v. Saunders, 199 F.3d 968, 973 (8th Cir. 1999)). However, “[a] pro se complaint must be liberally construed, and pro se litigants are held to a lesser pleading standard than other parties.” Topchian, 760 F.3d at 849 (internal quotation marks and citations omitted). But, because a pro se plaintiff “still must allege sufficient facts to support the claims advanced” (Stone v. Harry,

364 F.3d 912, 914 (8th Cir. 2004)) the pro se plaintiff must allege fraud with particularity in compliance with Rule 9(b). See Mayer v. Countrywide Home Loans, 647 F.3d 789, 792 (8th Cir. 2011). ANALYSIS OF THE COMPLAINT Smith’s allegations of fraud do not comply with Fed. R. Civ. P. 9(b), and without them, he does not state a plausible claim for relief, so his “complaint must be dismissed.” Bell Atlantic Corp., 550 U.S. at 569–70. The Court has diversity jurisdiction over Smith’s claim. Under 28 U.S.C. § 1332(a)(1), the Court has jurisdiction over state law disputes between “Citizens of different States” “where the matter in controversy exceeds the sum or value of $75,000.” Here, Humphrey and Hendricks are citizens of Texas and Smith is a citizen of Nebraska. Smith alleges there is $390,000 at issue. So, the Court has jurisdiction. Fed. R. Civ. P. 9(b) applies because Smith alleges fraud. Rule 9(b) applies if Smith’s claims “are grounded in fraud.” Collins v. Metro. Life Ins. Co., 117 F.4th 1010,

1017 (8th Cir. 2024). Here, while Smith’s specific cause of action is unclear, he alleges Defendants: “prepar[ed] and present[ed] false evidence,” “agreed to commit to act fraudulently to steal the Plaintiff’s real estate property,” and “knowingly, willingly, and deliberately prepar[ed] and summitt[ed] tampered physical evidence.” Filing No. 1 at 4- 5. And “Plaintiff is still suffering financial losses because of the Defendant’s successful criminal conspiracy that committed fraud.” Id. These allegations are grounded in fraud. Smith’s bare allegations do not allege fraud “with particularity” as required by Fed. R. Civ. P. 9(b). Rule 9(b) requires that a fraud claim “specify the time, place, and content of the defendant's false representations, as well as the details of the defendant's

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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)
Mayer v. Countrywide Home Loans
647 F.3d 789 (Eighth Circuit, 2011)
Samvel Topchian v. JPMorgan Chase Bank, N.A.
760 F.3d 843 (Eighth Circuit, 2014)
Parnes v. Gateway 2000, Inc.
122 F.3d 539 (Eighth Circuit, 1997)
Tommy Hopkins v. John Saunders
199 F.3d 968 (Eighth Circuit, 1999)

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Bluebook (online)
Smith v. Humphrey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-humphrey-ned-2025.