Spraggins v. Pierson

CourtDistrict Court, N.D. Texas
DecidedApril 22, 2025
Docket4:25-cv-00320
StatusUnknown

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

Bluebook
Spraggins v. Pierson, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

LASAE D. SPRAGGINS, § § Plaintiff, § § v. § Civil Action No. 4:25-cv-0320-O-BP § JUDGE DON PIERSON, § § Defendant. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court is the Complaint that pro se plaintiff LaSae D. Spraggins (“Spraggins”) filed March 24, 2025. ECF No. 1. Spraggins’s case was automatically referred to the undersigned pursuant to Special Order 3. ECF No. 2. After considering the pleadings and the applicable legal authorities, the undersigned RECOMMENDS that United States District Judge Reed O’Connor DISMISS Spraggins’s case pursuant to 28 U.S.C. § 1915(e)(2)(B)(i)–(ii). I. BACKGROUND In her Complaint, Spraggins alleges that Judge Don Pierson, presiding judge of Tarrant County Court at Law Number One, violated her civil rights. ECF No. 1. She alleges that Judge Pierson engaged in conduct that includes “coaching the plaintiff in an eviction case, improperly issuing a writ of possession after a vacated judgment, and denying the plaintiff’s request to stay the writ.” Id. at 1. She further asserts that Judge Pierson “violated [her] rights to due process and equal protection under the Fourteenth Amendment.” Id. Spraggins states that Judge Pierson’s actions “were taken in his official capacity as judge,” but she alleges further that “Judge Pierson acted outside his judicial capacity and exceeded the limits of his authority, thereby depriving [Spraggins] of [her] constitutional rights as a disabled pro se litigant.” Id. By Order dated April 1, 2025, the Court granted Spraggins’s Application to Proceed in District Court Without Prepaying Fees or Costs (ECF No. 5), subject to judicial screening under 28 U.S.C. § 1915. ECF No. 7. II. LEGAL STANDARD A. Screening under 28 U.S.C. § 1915(e)(2)(B)(i)-(ii)

The complaint of a plaintiff proceeding in forma pauperis is subject to sua sponte dismissal if it is “frivolous or malicious” or “fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2)(B)(i)–(ii). A complaint is frivolous if it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989); Brewster v. Dretke, 587 F.3d 764, 767 (5th Cir. 2009). A complaint lacks an arguable basis in law when it is “based on an indisputably meritless legal theory.” Neitzke, 490 U.S. at 326-27; Berry v. Brady, 192 F.3d 504, 507 (5th Cir. 1999). To state a viable claim for relief, Federal Rule of Civil Procedure 8 requires a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(1). To demonstrate entitlement to relief, the complaint must plead “enough facts to state a claim to

relief that is plausible on its face” with sufficient specificity to “raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). B. Pro se pleadings The Court subjects the pleadings of pro se parties to less rigid analysis than those of a party represented by counsel. “[A] pro se complaint, ‘however inartfully pleaded,’ must be held to ‘less stringent standards than formal pleadings drafted by lawyers.’” Estelle v. Gamble, 429 U.S. 97, 106 (1976) (citing Haines v. Kerner, 404 U.S. 519, 520 (1972)). However, “even a liberally- construed pro se . . . complaint must set forth facts giving rise to a claim on which relief may be granted.” Levitt v. Univ. of Tex. at El Paso, 847 F.2d 221, 224 (5th Cir. 1988) (citing Bounds v. Smith, 430 U.S. 817, 825-26 (1977)). Thus, a court inquires “whether within the universe of theoretically provable facts there exists a set which can support a cause of action under [the] complaint, indulgently read.” Covington v. Cole, 528 F.2d 1365, 1370 (5th Cir. 1976). There is a “well-established policy that the plaintiff be given every opportunity to state a claim.” Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001) (citing Hitt v. City of

Pasadena, 561 F.2d 606, 608 (5th Cir. 1977)). It is federal policy to decide cases on the merits rather than technicalities, and the Fifth Circuit thus recommends that suits be dismissed without prejudice on Rule 12 motions. Great Plains Tr. Co. v. Morgan Stanley Dean Witter & Co., 313 F.3d 305, 329 (5th Cir. 2002). As a result, courts generally allow plaintiffs at least one opportunity to amend following a Rule 12 dismissal on the pleadings, “unless it is clear that the defects are incurable.” Great Plains Tr. Co., 313 F.3d at 329. An incurable defect may arise when a complaint’s facts are “not actionable as a matter of law.” Id. In such situations, amendment would be futile, and dismissal with prejudice is appropriate. Schiller v. Physicians Res. Grp., Inc., 342 F.3d 563, 566 (5th Cir. 2003).

Courts may also appropriately dismiss an action with prejudice if the court finds that the plaintiff has alleged her best case. Jones v. Greninger, 188 F.3d 322, 327 (5th Cir. 1999). If the court “outline[s] in [its] opinion the deficiencies” of plaintiff's pleading and “plaintiff nevertheless cannot ... amend to satisfy [the relevant pleading standard,] the court can then dismiss the complaint with the assurance that the plaintiff has been shown all the deference he is due.” Sims v. Tester, No. 3:00-cv-0863-D, 2001 WL 627600, at *2-*3 (N.D. Tex. 2001). C. Judicial immunity “Like other forms of official immunity, judicial immunity is an immunity from suit, not just from ultimate assessment of damages.” Mireles v. Waco, 502 U.S. 9, 11 (1991). The immunity “is not overcome by allegations of bad faith or malice and ‘applies even when the judge is accused of acting maliciously and corruptly.’” Ballard v. Wall, 413 F.3d 510, 515 (5th Cir. 2005) (quoting Mireles, 502 U.S. at 11). It is overcome only by allegations that the judge's alleged misconduct is (1) “nonjudicial,” meaning action “not taken in the judge's judicial capacity” or (2) “judicial in nature,” yet “taken in the complete absence of all jurisdiction.” Mireles, 502 U.S. at 11-12. Because

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Related

Norman v. Apache Corp.
19 F.3d 1017 (Fifth Circuit, 1994)
Berry v. Brady
192 F.3d 504 (Fifth Circuit, 1999)
Schiller v. Physicians Resource Group Inc.
342 F.3d 563 (Fifth Circuit, 2003)
Ballard v. Wall
413 F.3d 510 (Fifth Circuit, 2005)
Brewster v. Dretke
587 F.3d 764 (Fifth Circuit, 2009)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Nixon v. Fitzgerald
457 U.S. 731 (Supreme Court, 1982)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Barbara W. Levitt v. University of Texas at El Paso
847 F.2d 221 (Fifth Circuit, 1988)

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Spraggins v. Pierson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spraggins-v-pierson-txnd-2025.