Sowell v. The State of Ohio

District Court, S.D. Ohio·Decided July 17, 2025·No. 2:25-cv-00355·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

SALVADORE J. SOWELL, : Case No. 2:25-cv-355 : Plaintiff, : : District Judge James L. Graham vs. : Magistrate Judge Elizabeth P. Deavers : STATE OF OHIO, : : Defendant. : : REPORT AND RECOMMENDATION

Plaintiff, a prisoner at the James A. Karnes Corrections Center, has filed a civil rights Complaint in this Court. (Doc. 1). By separate Order Plaintiff has been granted leave to proceed in forma pauperis.1 This matter is before the Court for a sua sponte review of the Complaint to determine whether the Complaint, or any portion of it, should be dismissed because it is frivolous, malicious, fails to state a claim upon which relief may be granted or seeks monetary relief from a Defendant who

1 Plaintiff has previously been denied leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915(g), the Prisoner Litigation Reform Act’s three-strikes provision. See Sowell v. Soc. Sec. Admin. Comm’r, Case No. 2:24-cv-3086 (S.D. Ohio Sept. 4, 2024) (Doc. 6, 11). In light of the Sixth Circuit’s recent decision in Crump v. Blue, 121 F.4th 1108 (2024), however, Plaintiff was not precluded from proceeding in forma pauperis under § 1915(g) at the time he filed his Complaint in this case. See Sowell v. United States of America, Case No. 2:25-cv-3 (S.D. Ohio Mar. 6, 2025) (Doc. 5 at PageID 41-43) (reviewing Plaintiff’s prior lawsuits and concluding that, under Crump, Plaintiff had not accumulated three strikes at the time of filing the complaint in that case) (Report and Recommendation), adopted (S.D. Ohio May 20, 2025). Although the Court has since determined that Plaintiff has again accumulated three strikes based on the dismissal of the complaint in Case No. 2:25-cv-3, see id. at Doc. 10, Plaintiff filed the instant action before this ruling. The Court therefore proceeds with the initial screen of the Complaint. is immune from such relief. See Prison Litigation Reform Act of 1995 § 804, 28 U.S.C. § 1915(e)(2)(B); § 805, 28 U.S.C. § 1915A(b). Screening of Plaintiff’s Complaint A. Legal Standard Congress enacted 28 U.S.C. § 1915, the federal in forma pauperis statute, seeking to “lower

judicial access barriers to the indigent.” Denton v. Hernandez, 504 U.S. 25, 31 (1992). In doing so, however, “Congress recognized that ‘a litigant whose filing fees and court costs are assumed by the public, unlike a paying litigant, lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits.’” Id. at 31 (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To address this concern, Congress included subsection (e)(2) as part of the statute, which provides in pertinent part: (2) Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that—

* * *

(B) the action or appeal—

(i) is frivolous or malicious;

(ii) fails to state a claim on which relief may be granted; or

(iii) seeks monetary relief against a defendant who is immune from such relief.

28 U.S.C. § 1915(e)(2)(B); Denton, 504 U.S. at 31. See also § 1915A(b). Thus, § 1915(e) requires sua sponte dismissal of an action upon the Court’s determination that the action is frivolous or malicious, or upon determination that the action fails to state a claim upon which relief may be granted.

2 Formerly 28 U.S.C. § 1915(d). To properly state a claim upon which relief may be granted, a plaintiff must satisfy the basic federal pleading requirements set forth in Federal Rule of Civil Procedure 8(a). See also Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (applying Federal Rule of Civil Procedure 12(b)(6) standards to review under 28 U.S.C. §§ 1915A and 1915(e)(2)(B)(ii)). Under Rule 8(a)(2), a complaint must contain a “short and plain statement of the claim showing that the pleader

is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Thus, Rule 8(a) “imposes legal and factual demands on the authors of complaints.” 16630 Southfield Ltd., P’Ship v. Flagstar Bank, F.S.B., 727 F.3d 502, 503 (6th Cir. 2013). Although this pleading standard does not require “‘detailed factual allegations,’ . . . [a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action’” is insufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). A complaint will not “suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557). Instead, to survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a complaint

must contain sufficient factual matter . . . to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). Facial plausibility is established “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “The plausibility of an inference depends on a host of considerations, including common sense and the strength of competing explanations for the defendant’s conduct.” Flagstar Bank, 727 F.3d at 504 (citations omitted). Further, the Court holds pro se complaints “‘to less stringent standards than formal pleadings drafted by lawyers.’” Garrett v. Belmont Cnty. Sheriff’s Dep’t., No. 08-3978, 2010 WL 1252923, at *2 (6th Cir. April 1, 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). This lenient treatment, however, has limits; “‘courts should not have to guess at the nature of the claim asserted.’” Frengler v. Gen. Motors, 482 F. App’x 975, 976–77 (6th Cir. 2012) (quoting Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989)). B. Allegations in the Complaint In its entirety, Plaintiff includes the following factual allegations in the Complaint:

The Plaintiff cannot receive a fair trial. In case numbers 22-CR-6073 and 6085; State of Ohio v. Salvatore J. Sowell, due to there being names of Franklin County Common Pleas Court judges listed on documents pertaining to a Huntington Bank lawsuit submitted in those cases aforementioned.

(Doc. 1-1, Complaint at PageID 8).

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