Wilfred L. Anderson, M.D. v. State of Ohio, et al.

CourtDistrict Court, S.D. Ohio
DecidedDecember 8, 2025
Docket2:25-cv-01325
StatusUnknown

This text of Wilfred L. Anderson, M.D. v. State of Ohio, et al. (Wilfred L. Anderson, M.D. v. State of Ohio, et al.) 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
Wilfred L. Anderson, M.D. v. State of Ohio, et al., (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

WILFRED L. ANDERSON, M.D.,

Plaintiff,

v. Civil Action 2:25-cv-1325 Judge Michael H. Watson Magistrate Judge Chelsey M. Vascura STATE OF OHIO, et al.,

Defendants.

ORDER and REPORT AND RECOMMENDATION Plaintiff, Wilfred L. Anderson, M.D., an Ohio resident proceeding without the assistance of counsel, sues the State of Ohio and the Ohio State Medical Board under 42 U.S.C. § 1983 for enforcing an allegedly void ab initio 1997 state-court conviction. Plaintiff 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 on Plaintiff’s Motion by Pro Se Litigant to Obtain Electronic Case Filing Rights (ECF No. 2). For good cause shown, the Motion (ECF No. 2) is GRANTED to the extent that Plaintiff may participate in e-filing only as to this particular case and conditional on his compliance with all applicable e-filing requirements. If he has not already done so, Plaintiff is DIRECTED to create a PACER account, and then complete the electronic filing registration for the Southern District of Ohio, as explained at https://pacer.uscourts.gov/register-account/non-attorney-filers-cmecf. Plaintiff is REMINDED that failure to adhere to all applicable e-filing requirements will likely result in the revocation of permission to participate in e-filing. Plaintiff is specifically CAUTIONED that failure to update his email address and monitor his email account (including his “junk mail” or spam folder) for court filings may result in the Court’s dismissal of the action.

Cf. Yeschick v. Mineta, 675 F.3d 622, 630 (6th Cir. 2012) (affirming district court’s denial of motion for relief from judgment where counsel’s neglect in failing to check docket until more than a month after he learned that he was not receiving notice of electronic filings because he failed to update his email address on file with the district court); Equal Emp’t Opportunity Comm’n v. Indi’s Fast Food Rest., Inc., No. 3:15-cv-00590, 2016 WL 7473130, at *6 (W.D. Ky. Dec. 28, 2016) (noting that defense counsel represented that “he did not receive any Court- related notices or emails because they were all sent to his ‘junk mail’ folder” and finding that “[d]efense counsel’s non-receipt of emails does not relieve his responsibility to monitor the Court’s docket and keep apprised of developments within his active cases, which he failed to do here”). Plaintiff is further CAUTIONED that his electronic filing access may be revoked at any

time. 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 lack of subject-matter jurisdiction. I. STANDARD OF REVIEW Under 28 U.S.C. § 1915(e), the federal in forma pauperis statute, Courts must sua sponte dismiss an action upon determining that an in forma pauperis complaint fails to state a claim on which relief can be granted. Thus, a typical initial screen involves consideration of the merits of the claims asserted. In this case, however, upon review of Plaintiff’s Complaint, the undersigned

determines that it is unnecessary to consider the merits of some of the claims he advances because this Court lacks subject-matter jurisdiction to hear such claims. When the face of the complaint provides no basis for federal jurisdiction, the Court may dismiss an action as frivolous and for lack of subject-matter jurisdiction under both 28 U.S.C. § 1915(e)(2)(B) and Federal Rule of Civil Procedure 12(h)(3). Williams v. Cincy Urb. Apts., No. 1:10-cv-153, 2010 WL 883846, at *2 n.1 (S.D. Ohio Mar. 9, 2010) (citing Carlock v. Williams, 182 F.3d 916, 1999 WL 454880, at *2 (6th Cir. June 22, 1999) (table)). II. ANALYSIS Plaintiff alleges that in 1997, he was convicted of a misdemeanor offense in the Court of Common Pleas for Cuyahoga County, Ohio. Plaintiff further alleges that this conviction was

“jurisdictionally void ab initio because the mandatory two-year statute of limitations (SOL) had expired well before the commencement of prosecution.” (Compl. ¶ 2, ECF No. 1-1.) The conviction led to the permanent revocation of Plaintiff’s medical license. Plaintiff alleges he suffered catastrophic personal and financial harm, which was compounded by the state courts’ arbitrary refusal to recognize and correct the void judgment. Plaintiff seeks declaratory and injunctive relief against the State of Ohio and the Ohio State Medical Board. Plaintiff’s claims are barred by the doctrine of sovereign immunity. The Eleventh Amendment operates as a bar to federal-court jurisdiction when a private citizen sues a state or its instrumentalities unless the state has given express consent. Pennhurst St. Sch. & Hosp. v. Halderman, 465 U.S. 89, 100 (1983); Lawson v. Shelby Cty., 211 F.3d 331, 334 (6th Cir. 2000). “There are three exceptions to sovereign immunity: (1) when the state has waived immunity by consenting to the suit, (2) when Congress has expressly abrogated the states’ sovereign immunity, and (3) when the doctrine set forth in Ex Parte Young, 209 U.S. 123, 28 S.Ct. 441, 52

L.Ed. 714 (1908), applies.” Boler v. Earley, 865 F.3d 391, 410 (6th Cir. 2017) (citation omitted). None of these exceptions apply to Plaintiff’s Complaint. First, “Ohio has not waived sovereign immunity in federal court.” Mixon v. State of Ohio, 193 F.3d 389, 397 (6th Cir. 1999). Second, “Section 1983 does not abrogate Eleventh Amendment immunity.” Boler, 865 F.3d at 410 (citing Will, 491 U.S. at 66). Third, the Ex Parte Young doctrine applies only when a plaintiff brings “claims for prospective relief against state officials sued in their official capacity to prevent future federal constitutional or statutory violations.” Boler, 865 F.3d at 412. But Plaintiff sues only the State of Ohio and the Ohio State Medical Board, not any state officials. Accordingly, no exception to sovereign immunity applies and Plaintiff’s Complaint must be dismissed. Even if Plaintiff were to amend his Complaint to sue a state official in his or her official

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Pennhurst State School and Hospital v. Halderman
465 U.S. 89 (Supreme Court, 1984)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
544 U.S. 280 (Supreme Court, 2005)
Yeschick v. Mineta
675 F.3d 622 (Sixth Circuit, 2012)
In Re Cook
551 F.3d 542 (Sixth Circuit, 2009)
Boler v. Earley
865 F.3d 391 (Sixth Circuit, 2017)

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