Thompson v. Ohio Dept. of Rehab & Corrections

CourtDistrict Court, S.D. Ohio
DecidedApril 29, 2025
Docket2:25-cv-00143
StatusUnknown

This text of Thompson v. Ohio Dept. of Rehab & Corrections (Thompson v. Ohio Dept. of Rehab & Corrections) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. Ohio Dept. of Rehab & Corrections, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

GOLDY THOMPSON, : Case No. 2:25-cv-143 : Plaintiff, : : Chief District Judge Sarah D. Morrison vs. : Magistrate Judge Kimberly A. Jolson : OHIO DEPARTMENT OF : REHABILITATION AND : CORRECTIONS, et al., : : Defendants.

ORDER AND REPORT AND RECOMMENDATION

Plaintiff, a prisoner at Chillicothe Correctional Institution (CCI), has filed a pro se civil rights Complaint in this Court under 42 U.S.C. § 1983. (Doc. 1-1). Plaintiff names eighteen Defendants: the Ohio Department of Rehabilitation and Correction (ODRC); CCI; Annette Chambers-Smith, Director of ODRC; CCI Warden Shoop; Chief Inspector Morrow; Inspector Lambert; Inspector Free; Captain Ramirez; Lieutenant Cannon; J. Currior; Unit Manager Ivey; T. Napier; Mailroom processors Mr. Spaiol, Ms. Coon, and Mr. Gillion; and Corrections Officers Patrick, Williams, and Strausbaugh. By separate Order, Plaintiff has been granted leave to proceed in forma pauperis under 28 U.S.C. § 1915. This matter is before the Court for a sua sponte review of Plaintiff’s 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 is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). Having performed the initial screen, Plaintiff MAY PROCEED on his First Amendment legal mail claim against some Defendants in their individual capacity, as well as in their official capacity to the extent Plaintiff seeks injunctive and declaratory relief. However, the Undersigned RECOMMENDS that Plaintiff’s remaining claims be DISMISSED. I. SCREENING OF THE COMPLAINT

A. Legal Standard In enacting the original in forma pauperis statute, 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.” Denton v. Hernandez, 504 U.S. 25, 31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). To prevent such abusive litigation, Congress has authorized federal courts to dismiss an in forma pauperis complaint if they are satisfied that the action is frivolous or malicious. Id.; see also 28 U.S.C. § 1915(e)(2)(B)(i). A complaint may be dismissed as frivolous when the plaintiff cannot make any claim with a rational or arguable basis in fact or law. Neitzke v. Williams, 490 U.S. 319, 328–29 (1989); see also Lawler v. Marshall, 898 F.2d 1196, 1198 (6th Cir. 1990). An action has

no arguable legal basis when the defendant is immune from suit or when the plaintiff claims a violation of a legal interest which clearly does not exist. Neitzke, 490 U.S. at 327. An action has no arguable factual basis when the allegations are delusional or rise to the level of the irrational or “wholly incredible.” Denton, 504 U.S. at 32; Lawler, 898 F.2d at 1199. The Court need not accept as true factual allegations that are “fantastic or delusional” in reviewing a complaint for frivolousness. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (quoting Neitzke, 490 U.S. at 328). Congress also has authorized the sua sponte dismissal of complaints that fail to state a claim upon which relief may be granted. 28 U.S.C. § 1915(e)(2)(B)(ii). A complaint filed by a pro se plaintiff must be “liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97, 106 (1976)). Even so, the complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft

v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Hill, 630 F.3d at 470–71 (“[D]ismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim [under §§ 1915A(b)(1) and 1915(e)(2)(B)(ii)].”) “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). The Court must accept all well-pleaded factual allegations as true but need not “accept as true a legal conclusion couched as a factual allegation.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). Although a complaint need not contain “detailed factual allegations,” it must provide “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678

(citing Twombly, 550 U.S. at 555). A pleading that offers “labels and conclusions” or “a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor does a complaint suffice if it tenders “naked assertion[s]” devoid of “further factual enhancement.” Id. at 557. The complaint must “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Erickson, 551 U.S. at 93 (citations omitted). B. Allegations in the Complaint Plaintiff’s Complaint consists of fifty numbered paragraphs, and Plaintiff does not separately delineate the specific claims he pleads. (Doc. 1-1). The Undersigned construes the Complaint as attempting to set forth First Amendment claims regarding the improper handling and delivery of his legal mail and denial of his right to access the courts, denial of his informal complaints and grievances, retaliation by CCI staff, and violations of several administrative policies and rules regarding employee conduct. To begin, Plaintiff alleges that ODRC’s and CCI’s legal mail policy violates his First

Amendment rights. (Id. at ¶¶ 1–3). Plaintiff explains that on September 28, 2024, and October 16, 2024, CCI mailroom staff opened and made copies of his legal mail outside his presence. (Id. at ¶¶ 3–5). Defendant Williams delivered that mail through the regular mail process, and on the first occasion, delivered Plaintiff’s legal mail to the wrong inmate. (Id.). After the second incident, Plaintiff began filing informal complaints and grievances. (Id. at ¶¶ 6–9). Plaintiff was informed that his mail was not treated as legal mail because it lacked the requisite control number required by ODRC administrative rules. (Id. at ¶ 16; see also id. at 24). According to Plaintiff, Defendants violated his right to access the courts and his right to confidentiality in a legal case. (Id. at ¶ 50).

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Monell v. New York City Dept. of Social Servs.
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Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Regents of University of California v. Doe
519 U.S. 425 (Supreme Court, 1997)
Lapides v. Board of Regents of Univ. System of Ga.
535 U.S. 613 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
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Colvin v. Caruso
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Hill v. Lappin
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Bellamy v. Bradley
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Thompson v. Ohio Dept. of Rehab & Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-ohio-dept-of-rehab-corrections-ohsd-2025.