Souare v. Summit County, Ohio

CourtDistrict Court, N.D. Ohio
DecidedAugust 12, 2025
Docket5:25-cv-01209
StatusUnknown

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

Bluebook
Souare v. Summit County, Ohio, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

ELHADJ ALPHA MAHMOUD SOUARE, ) CASE NO. 5:25 CV 1209 ) Plaintiff, ) JUDGE JOHN R. ADAMS ) v. ) ) MEMORANDUM OF OPINION SUMMIT COUNTY, ) AND ORDER ) Defendant. )

Pro se Plaintiff Elhadj Alpha Mahmoud Souare filed this action under 42 U.S.C. § 1983 against Summit County, Ohio to contest the actions of the Summit County Child Support Enforcement Agency (“CSEA”) to suspend his driver’s license for nonpayment of child support. He claims CSEA did not provide him with advanced notice of their intent to seek suspension of his license and did not provide an opportunity for him to contest the penalty. He also alleges that CSEA failed to exhaust less restrictive means to enforce the child support obligation. He states, without explanation, that Summit County is liable for “unconstitutional policies, practices or customs under Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978).” (Doc. No. 1 at PageID #: 2). He seeks monetary damages. I. Background Plaintiff’s Complaint contains very few factual allegations and is composed largely of conclusory statements. He contends that Summit County, acting through CSEA, suspended his driver’s license on December 10, 2024 based solely on non-payment of child support. He claims he did not receive advanced notice of the suspension and was not given the opportunity to pay the arrearage to avoid the suspension. He claims that this is a denial of due process. He also contends that CSEA did not choose the least restrictive means of obtaining payment of the arrearage, suggesting instead that a garnishment would be more useful to achieve that goal. He

contends the penalty is excessive in violation of the Eighth Amendment and that he was denied a jury trial in violation of the Seventh Amendment. He states that his race was a motivating factor in the enforcement of policies and states without explanation that black obligors are treated differently in violation of the Equal Protection Clause. He also claims that CSEA retaliated against him for filing a public records request. He states that “the unconstitutional actions were undertaken pursuant to the official policy, custom, or practice of Summit County and CSEA.” (Doc. No. 1 at PageID #: 3). The Defendant filed a Motion for Judgment on the Pleadings pursuant to Federal Civil Procedure Rule 12(c). (Doc. No. 7). They assert that Summit County cannot be held liable for the actions of CSEA Employees under a theory of respondeat superior and Plaintiff failed to

plead sufficient facts to establish a specific policy of Summit County that would support liability. II. Standard of Review The Federal Rules of Civil Procedure provide that, “after the pleadings are closed—but early enough not to delay trial—a party may move for judgment on the pleadings.” Fed.R.Civ.P. 12(c). Judgment may be granted under Rule 12(c) where the moving parties clearly establish that no material issue of fact remains to be resolved and that they are entitled to judgment as a matter of law. Beal v. Missouri Pacific R.R., 312 U.S. 45, 61 S.Ct. 418, 85 L.Ed. 577 (1941). A Motion for Judgment on the Pleadings under Rule 12(c) is subject to the same standard of review as a Rule 12(b)(6) Motion. Penny/Ohlmann/Nieman, Inc. v. Miami Valley Pension Corp., 399 F.3d 692, 697 (6th Cir. 2005). Accordingly, in reviewing a Motion for Judgment on the Pleadings under Rule 12(c), the Court must construe the Complaint in a light most favorable to the Plaintiff, accept all well-pled factual allegations as true, and determine whether the Plaintiff undoubtedly can prove no set of facts in support of those allegations that would entitle him to

relief. Bishop v. Lucent Technologies, Inc., 520 F.3d 516, 519 (6th Cir. 2008) (citing Harbin– Bey v. Rutter, 420 F.3d 571, 575 (6th Cir. 2005)). To survive a Motion for Judgment on the Pleadings, the “Complaint must contain either direct or inferential allegations respecting all material elements to sustain a recovery under some viable legal theory.” Id. (quoting Mezibov v. Allen, 411 F.3d 712, 716 (6th Cir. 2005)). Under Federal Rule of Civil Procedure 8(a)(2), a Complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” This pleading standard does not require ‘detailed factual allegations.’ “ Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). The factual allegations in the pleading, however, must be sufficient to raise the right to relief above the speculative level

on the assumption that all the allegations in the Complaint are true. Twombly., 550 U.S. at 555. The Plaintiff is not required to include detailed factual allegations, but must provide more than “an unadorned, the-Defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. III. Analysis Plaintiff’s Complaint is composed largely of legal conclusion and is devoid of factual allegations to explain or support his statements. Although this Court recognizes that pro se pleadings are to be held to a less stringent standard than formal pleadings drafted by lawyers, Haines v. Kerner, 404 U.S. 519, 520-21 (1972); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir.1991), the Court is not required to conjure up unpled allegations. Bassett v. National Collegiate Athletic Ass’n, 528 F.3d 426, 437 (6th Cir. 2008). The Complaint must give the Defendants fair notice of what the Plaintiff’s legal claims are and the factual grounds upon which

they rest. In this case, Plaintiff is attempting to hold Summit County liable for the actions of individuals at the Summit County CSEA by simply stating that Summit County is liable for “unconstitutional policies, practices or customs.” (Doc. No. 1 at PageID #: 2). This is not sufficient to state a claim for relief against Summit County. Section 1983 does not permit a Plaintiff to sue a local government entity on the theory of respondeat superior. Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658, 692- 94 (1978). A Plaintiff may only hold a local government entity liable under § 1983 for the entity's own wrongdoing. Id.

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Related

Beal v. Missouri Pacific R. Corp.
312 U.S. 45 (Supreme Court, 1941)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
James M. Jourdan, Jr. v. John Jabe and L. Boyd
951 F.2d 108 (Sixth Circuit, 1991)
Feliciano v. City of Cleveland
988 F.2d 649 (Sixth Circuit, 1993)
Lloyd D. Alkire v. Judge Jane Irving
330 F.3d 802 (Sixth Circuit, 2003)
Keith Harbin-Bey v. Lyle Rutter
420 F.3d 571 (Sixth Circuit, 2005)
Bishop v. Lucent Technologies, Inc.
520 F.3d 516 (Sixth Circuit, 2008)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Stemler v. City of Florence
126 F.3d 856 (Sixth Circuit, 1997)

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