Thomas E. Forbush, Jr. v. J. Christian Lampe and Joshua Orlowski

CourtDistrict Court, E.D. Tennessee
DecidedDecember 11, 2025
Docket2:25-cv-00023
StatusUnknown

This text of Thomas E. Forbush, Jr. v. J. Christian Lampe and Joshua Orlowski (Thomas E. Forbush, Jr. v. J. Christian Lampe and Joshua Orlowski) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas E. Forbush, Jr. v. J. Christian Lampe and Joshua Orlowski, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT GREENEVILLE

THOMAS E. FORBUSH, JR., ) ) Plaintiff, ) ) v. ) No. 2:25-CV-00023-DCLC-CRW ) J. CHRISTIAN LAMPE and JOSHUA ) ORLOWSKI, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

This matter is before the Court on United States Magistrate Judge Cynthia R. Wyrick’s Report and Recommendation [Doc. 4] and Plaintiff Thomas E. Forbush, Jr.’s Objections [Doc. 5]. For the reasons herein, the Court will overrule Mr. Forbush’s objections. I. BACKGROUND

In 2019, a federal grand jury indicted Mr. Forbush on charges under the Controlled Substances Act, 21 U.S.C. § 801 et seq. [Superseding Indictment, Doc. 77, at 1–2, No. 2:18- CR-00148-DCLC-CRW]. He entered into a plea agreement with the United States and pleaded guilty to aiding and abetting possession with the intent to distribute five grams or more of methamphetamine, in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(B) and 18 U.S.C. § 2. [Plea Agreement, Doc. 191, at 1, No. 2:18-CR-001481-DCLC-CRW]. The Court sentenced him to sixty months’ imprisonment and a five-year term of supervised release. [J., Doc. 436, at 2–3, No. 2:18-CR-00148-DCLC-CRW]. Although he has completed his federal custodial sentence, he is currently a state prisoner serving a custodial sentence in Sullivan County, Tennessee. Acting pro se, he now brings suit against Defendants J. Christian Lampe, the Assistant United States Attorney who prosecuted him, and Agent Joshua Orlowski, the law-enforcement agent who investigated him and who is member of a task force between the Drug Enforcement Administration and the Tennessee Bureau of Investigation. Mr. Forbush alleges that Mr. Lampe and Agent Orlowski violated his civil rights because they “with held [sic] discovery” in his criminal case. [Compl., Doc. 2, at 3]. Seeking redress under 42 U.S.C. § 1983, he requests the

“reopen[ing] or dismiss[al]” of his criminal case, Mr. Lampe’s disbarment, and the initiation of criminal charges against Mr. Lampe and Agent Orlowski. [Id. at 5]. Magistrate Judge Wyrick has now screened Mr. Forbush’s complaint under 28 U.S.C. § 1915(e)(2)(B), and she recommends the Court dismiss his § 1983 claims—which she has construed as claims for a violation of his due-process rights under the Fourteenth Amendment and Brady v. Maryland, 373 U.S. 83 (1963).1 Mr. Forbush now objects to her report and recommendation, and the Court, having carefully considered his objections, is now prepared to rule on them.

II. LEGAL STANDARD

When reviewing a magistrate judge’s recommendation on a dispositive issue, the Court conducts a de novo review of that recommendation. 28 U.S.C. § 636(b)(1); Fed. R. Civ P. 72(b)(3). A magistrate judge’s recommendation of dismissal under 28 U.S.C. § 1915(e)(2)(B) is dispositive in nature. See Hill v. Lappin, 630 F.3d 468, 470–71 (6th Cir. 2010) (stating that “the dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim under [§§ 1915(e)(2)(B)(ii) and 1915A]”). A de novo review requires the Court “to give fresh consideration” to the issues before it. United States v. Raddatz, 447 U.S. 667, 675

1 In Brady, the Supreme Court held that “the suppression by the prosecution of evidence favorable to an accused . . . violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. 373 U.S. at 87. In short, “Brady proscribes withholding evidence ‘favorable to an accused’ and material to [his] guilt or to punishment.’” Skinner v. Switzer, 562 U.S. 521, 536 (2011) (alterations in original) (quoting Cone v. Bell, 556 U.S. 449, 451 (2009)). (1980) (quotation omitted). In doing so, the Court reaches “the ultimate determination of the matter” through its own judicial discretion. Id. at 675–66. After its review, it “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1).

III. ANALYSIS

In recommending the dismissal of Mr. Forbush’s claim against Mr. Lampe, Magistrate Judge Wyrick states that Mr. Lampe is entitled to absolute prosecutorial immunity. [R. & R. at 9]. And in recommending the dismissal of Mr. Forbush’s claim against Agent Orlowski, she states that Mr. Forbush fails to allege that “the suppressed evidence would have produced a different verdict,” [id. at 7 (quoting Strickler v. Greene, 527 U.S. 263, 281 (1999)], that his plea agreement contains facts that undercut his claim, [id. at 8], and that the documents attached to his complaint “make[] it clear” that a different law-enforcement officer and not Agent Orlowski withheld the discovery in question, [id. at 9]. In now challenging Magistrate Judge Wyrick’s recommendation of dismissal, Mr. Forbush does not object to her depiction of his claims as Brady claims. Instead, he describes her conclusion that Mr. Lampe is entitled to absolute prosecutorial immunity as “bull” and continues to insist that Mr. Lampe and Agent Orlowski withheld evidence. [Pl.’s Objs. at 3–4]. The Court begins by noting that Mr. Forbush does not specify whether he is suing Mr. Lampe and Agent Orlowski in their official or individual capacities. An official-capacity claim differs from an individual-capacity claim under § 1983. An official-capacity claim attaches liability only to a government entity, whereas an individual-capacity claim attaches personal

liability to a government official for an alleged wrongdoing under color of law. Essex v. County of Livingston, 518 F. App’x 351, 354–55 (6th Cir. 2013); see Cady v. Arenac County, 574 F.3d 334, 342 (6th Cir. 2009) (“In an official capacity action, the plaintiff seeks damages not from the individual officer, but from the entity for which the officer is an agent.” (quotation omitted)). Despite Mr. Forbush’s failure to specify whether he is alleging official-capacity claims or individual-capacity claims, or both, the Court can narrow his claims to individual-capacity claims based on the fact that they are clearly Bivens claims.2 They are Bivens claims because

they involve allegations against federal law-enforcement officers who were allegedly acting in their federal law-enforcement capacities. See Dolan v. United States, 514 F.3d 587, 594 n.2 (6th Cir. 2008) (“A Bivens claim . . . is a claim for money for injuries sustained as a result of a federal agent’s violation of the constitution while acting under his federal authority.” (citing Bivens v. Six Unknown Named Agents of Fed.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Carey v. Piphus
435 U.S. 247 (Supreme Court, 1978)
Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
United States v. Raddatz
447 U.S. 667 (Supreme Court, 1980)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Strickler v. Greene
527 U.S. 263 (Supreme Court, 1999)
Cone v. Bell
556 U.S. 449 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Sanford J. Berger v. Samuel R. Pierce
933 F.2d 393 (Sixth Circuit, 1991)
Cady v. Arenac County
574 F.3d 334 (Sixth Circuit, 2009)
Dolan v. United States
514 F.3d 587 (Sixth Circuit, 2008)
Tyron Brown v. Lee Lucas
753 F.3d 606 (Sixth Circuit, 2014)
Curen Essex v. County of Livingston
518 F. App'x 351 (Sixth Circuit, 2013)
Thomas Ross v. Warden Francisco Pineda
549 F. App'x 444 (Sixth Circuit, 2013)
James King v. United States
917 F.3d 409 (Sixth Circuit, 2019)
Brownback v. King
592 U.S. 209 (Supreme Court, 2021)

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Thomas E. Forbush, Jr. v. J. Christian Lampe and Joshua Orlowski, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-e-forbush-jr-v-j-christian-lampe-and-joshua-orlowski-tned-2025.