Washington v. Red Roof

CourtDistrict Court, S.D. Ohio
DecidedJuly 9, 2025
Docket2:25-cv-00707
StatusUnknown

This text of Washington v. Red Roof (Washington v. Red Roof) 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
Washington v. Red Roof, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ROOSEVELT WASHINGTON,

Plaintiff,

v. Civil Action 2:25-cv-707 Judge Edmund A. Sargus, Jr. Magistrate Judge Chelsey M. Vascura RED ROOF,

Defendant.

ORDER and REPORT AND RECOMMENDATION Plaintiff, Roosevelt Washington, an Ohio resident proceeding without the assistance of counsel, has submitted a request to file a civil action in forma pauperis. (ECF No. 1.) The Court GRANTS Plaintiff’s request to proceed in forma pauperis. All judicial officers who render services in this action shall do so as if the costs had been prepaid. 28 U.S.C. § 1915(a). This matter is also before the Court for the initial screen of Plaintiff’s Complaint (ECF No. 1-1) under 28 U.S.C. § 1915(e)(2) to identify cognizable claims and to recommend dismissal of Plaintiff’s Complaint, or any portion of it, which 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). Having performed the initial screen, for the reasons below, the undersigned RECOMMENDS that the Court DISMISS this action under § 1915(e)(2)(B) for failure to state a claim on which relief can be granted. I. STANDARD OF REVIEW 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) 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; [or] (ii) fails to state a claim on which relief may be granted . . . . 28 U.S.C. § 1915(e)(2)(B)(i) & (ii); Denton, 504 U.S. at 31. 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. To 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) (cleaned up). A complaint will not “suffice if it tenders naked assertion devoid of further factual enhancement.” Id. (cleaned up).

Instead, to state a claim upon which relief may be granted, “a complaint must contain sufficient factual matter to state a claim to relief that is plausible on its face.” Id. (cleaned up). 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 Cty. Sheriff’s Dep’t, 374 F. App’x 612, 614 (6th Cir. 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)). II. ANALYSIS Plaintiff alleges that he has information about financial crimes that he has shared with out-of-state FBI representatives. Perhaps in retaliation for sharing this information, unspecified “people, group[s], or organization[s]” have bought several homes that Plaintiff has rented for the purpose of evicting him. These unspecified individuals or entities have also bribed the owners of hotels (in which Plaintiff has stayed since his rental homes were sold) to kick Plaintiff out. Plaintiff further alleges that “they are bringing the homeless into Columbus, Ohio by Greyhound under cover of darkness from other states.” In his prayer for relief, Plaintiff asks for assistance “with the agency violating my civil rights.” (Compl., ECF No. 1-1.) Although the Complaint caption names “Red Roof” as the sole Defendant (presumably referring to Red Roof Inn, the business located at the address Plaintiff lists for Defendant) the Complaint contains no allegations pertaining to Red Roof Inn.

Plaintiff’s allegations are threadbare and do not give rise to any cognizable cause of action. Even if the Court construed the Complaint to allege that Defendant Red Roof Inn accepted bribes for the purpose of evicting Plaintiff in retaliation for his FBI informant activities, the Complaint identifies no state or federal authority creating a cause of action for this conduct.1 Nor is any readily apparent to the Court. Although providing information to the FBI may be protected by the First Amendment, claims for First Amendment retaliation may be brought only against state actors. See, e.g., Reguli v. Russ, 109 F.4th 874, 880 (6th Cir. 2024).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jeremy Garrett v. Belmont County Sheriff's Dep't
374 F. App'x 612 (Sixth Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Neil Frengler v. General Motors
482 F. App'x 975 (Sixth Circuit, 2012)
Booth v. Henson
290 F. App'x 919 (Sixth Circuit, 2008)
Wells v. Brown
891 F.2d 591 (Sixth Circuit, 1989)
Connie Reguli v. Lori Russ
109 F.4th 874 (Sixth Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Washington v. Red Roof, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-red-roof-ohsd-2025.