Steven Bradley v. Tarrant County, Texas, et al.

CourtDistrict Court, N.D. Texas
DecidedSeptember 25, 2025
Docket4:25-cv-00866
StatusUnknown

This text of Steven Bradley v. Tarrant County, Texas, et al. (Steven Bradley v. Tarrant County, Texas, et al.) 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
Steven Bradley v. Tarrant County, Texas, et al., (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION STEVEN BRADLEY § V. CIVIL NO, 4:25-CV-866-P TARRANT COUNTY, TEXAS, ET AL. : FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE This case is now before the Court for review of pro se Plaintiff Steven Bradley’s civil suit. In this case, Plaintiff is proceeding in forma pauperis and, as such, his pleadings are subject to preliminary screening pursuant to 28 U.S.C. § 1915(e)(2)(B). Pursuant to this statute, the Court shall, sua sponte, dismiss a case proceeding IFP if the court determines that, infer alia, it is frivolous or fails to state a claim on which relief may be granted. See id. On August 12, 2025, Bradicy filed a Complaint [doc. 1] in the above-styled and numbered action, Subsequently, on August 19, 2025, the Court granted Plaintiff leave to proceed in forma pauperis [doc. 17]. That same day, the Court, after noting that two similar cases were recently consolidated with this case, ordered Plaintiff to file an amended complaint no later than September 3, 2025 [doc. 19]. On August 22, 2025, Plaintiff filed an Amended Complaint [doc. 20], which is the live pleading before this Court. In his Amended Complaint, Plaintiff sues the following: (1) “Tarrant County, Texas (in official capacity); (2) “Justice of the Peace, Precinct |, Tarrant County (in official capacity); and (3) “Tarrant County Clerk (in official capacity).) (Plaintiff's Amended Complaint (“Pl.’s Am. Compl.” at 1-2.) Plaintiff alleges multiple state and federal constitutional claims, statutory and other claims against Defendants for denying him access to Tarrant County Justice of the Peace

Court, Precinct { (“JP Court, Precinct 1”). (See generally Plaintiff's Amended Complaint (“PL.’s Am, Compl.”) Specifically, Plaintiff claims that his access to such court was denied when court staff forced him “to use an electronic filing system with ... vulnerabilities” and refused to accept his in-person filing, (Pl.’s Am. Compl. at 2, 5.) Bradley attaches to his Amended Complaint several documents purporting to show his multiple attempts to efile a case in JP Court, Precinct 1 against Capital One Bank (USA), N.A. (“Capital One Bank”) and the rejection of such attempts. (Pl.’s Am. Compl, Exhibit (“Ex.”) 11.) Bradley seeks injunctive relief “requiring JP1 to accept his [in-person] filings and legal tender.” (PI.’s Am. Compl. at 7.) Federal Rule of Civil Procedure (“Rule”) 8(a)(2) directs that a “pleading that states a claim for relief 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). A plaintiff, however, must plead specific facts, not mere conclusory allegations, to avoid dismissal. See Schultea v. Wood, 47 F.3d 1427, 1431 (Sth Cir. 1995) (en banc); see also Taylor v. Books A Million, Inc., 296 F.3d 376, 378 (Sth Cir, 2002) (“fC]onclusory allegations or legal conclusions masquerading as factual conclusions will not suffice to prevent a motion to dismiss” (internal quotation marks omitted)). Rule 8 “demands more than an unadorned, the-defendant-unlawfully-harmed-me-accusation.” Ashcroft v. [gbal, 556 U.S. 662, 678 (2009), In screening Bradley’s case, the Court may rely on Bradley’s complaint and attached documents as well as “‘documents incorporated into the complaint by reference and matters of which a court may take judicial notice.” Benavides v. Harlingen Police Dep't, No. 1:24-cv-179, 2025 WL 1477011, at *3 (S.D. Tex. Apr. 2025) (quoting Dorsey v. Portfolio Equities, Ine., 540 F.3d 333, 338 (Sth Cir, 2008)); see also Fed. R. Evid. 201(f) advisory committee’s note (“[JJudicial notice may be taken at any stage of the proceeding.”).

Moreover courts have generally held that “there is no denial of access to courts if alternative means of assuring access to courts were available.” Williams v. Curtis, No, 3:16-CV- 151-D-BH, 2017 WL 979053, at *6 (N.D. Tex. Jan. 18, 2017), In addition, “to prevail on an access to courts claim, a [claimant] must demonstrate prejudice or harm by showing that his ability to pursue a ‘nonfrivolous,’ ‘arguable’ legal claim was hindered by the defendants’ actions.” Wilson v, Tex. Civ. Commitment Cent, Facility Dir., No. 5:20-CV-267-H-BQ, 2021 WL 2653528, at *3 (N.D. Tex. May If, 2021). In other words, Plaintiff ““‘must demonstrate that the lack of access has prevented him from filing or caused him to lose a pending case.’” /d. (quoting Foreman v. Bowles, No. 3:01-CV-2117-G, 2003 WL. 21730136, at *3 (N.D. Tex, Mar. 31, 2003)). “There is no constitutional violation when a [claimant] has time to submit legal documents in a court despite impediments caused by officials.” Russie v. Davis, No, 2:17-CV-225-2-BR, 2020 WL 6550502, at *4 (N.D. Tex. Nov. 5, 2020). “A civil rights claim cannot be based on ‘minor and short-lived impediments to access’ in the absence of actual prejudice.” Jd. (citing Chandler v. Baird, 926 F.2d 1057, 1063 (Sth Cir, 1991)). Having reviewed the allegations in Plaintiff's Amended Complaint, the Court FINDS and CONCLUDES that Plaintiff has, as the very least, failed to state a claim for denial of access to the courts. While Bradley alleges that he has no alternative means to access the JP Court, Precinct 1, “to sufficiently plead an access-to-courts claim, even a non-prisoner[, such as Bradley,] must plead that ‘official acts... may allegedly have caused the loss ... of a meritorious case.” Sanders v. Rose, 576 F, App’x 91, 94 (3rd Cir. 2014) (quoting Christopher v. Harbury, 536 U.S. 403, 416 (2002}). In this case, it is clear that any alleged acts by Defendants did not actually result in the loss of Bradley’s ability to file a meritorious case in JP Court, Precinct 1. To begin with, a search of JP Court, Precinct 1’s public court records, which this Court takes judicial notice of, shows that

Bradley, on September [1, 2025, successfully filed at least five pending cases in JP Court, Precinct One such suit filed by Bradley, case no. JP01-25-SC00017109, is against Capitol One Bank,” the same defendant that Bradley referenced in the exhibits attached to his Amended Complaint that he was allegedly not allowed to file suit against. The docket entry in this case in JP Court, Precinct | shows that the original petition was filed “IN PERSON/BY PLTF.” (See Ex, B.) Thus, Bradley has been allowed to file his case in JP Court, Precinct | in person. In addition, Bradley has failed to ailege in his Amended Complaint any facts indicating that the underlying claim he was trying to file (and has now successfully filed) against Capital One Bank in JP Court, Precinct | is meritorious or nonfrivolous. See, e.g., Wilson, 2021 WL 2653528, at *3 (stating that “to prevail on an access to courts claim a [claimant] must demonstrate prejudice by showing that his ability to pursue a nonfrivolous, arguable legal claim was hindered by the defendants’ actions”) (internal quotation marks omitted).) Consequently, the Court FINDS and CONCLUDES that Bradley has failed to state a valid claim upon which relief can be granted.

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Related

Taylor v. Books a Million, Inc.
296 F.3d 376 (Fifth Circuit, 2002)
Dorsey v. Portfolio Equities, Inc.
540 F.3d 333 (Fifth Circuit, 2008)
Christopher v. Harbury
536 U.S. 403 (Supreme Court, 2002)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jim Eric Chandler v. Captain William Baird
926 F.2d 1057 (Eleventh Circuit, 1991)
Joseph Chhim v. University of Texas at Austin
836 F.3d 467 (Fifth Circuit, 2016)

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Bluebook (online)
Steven Bradley v. Tarrant County, Texas, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-bradley-v-tarrant-county-texas-et-al-txnd-2025.