Williams v. Warren County

District Court, S.D. Ohio·Decided October 19, 2022·No. 1:22-cv-00153·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

Thomas C. Williams,

Plaintiff, Case No. 1:22-cv-153

v. Judge Michael R. Barrett

Warren County,

Defendant.

ORDER This matter is before the Court on the Magistrate Judge’s March 29, 2022 Report and Recommendations (“R&R”) recommending that this action be dismissed with prejudice for failure to state a claim for relief; and recommending that pursuant to 28 U.S.C. § 1915(a) that an appeal of any order adopting the R&R would not be taken in good faith and therefore Plaintiff should be denied leave to appeal in forma pauperis. (Doc. 5). Plaintiff has filed Objections to the R&R. (Doc. 6). I. BACKGROUND Plaintiff filed a pro se complaint against Defendant Warren County on March 24, 2022, along with a Motion for Leave to Proceed in forma pauperis pursuant to 28 U.S.C. § 1915. (Doc. 1). On March 29, 2022, the Magistrate Judge granted Plaintiff’s Motion for Leave to Proceed in forma pauperis. (Doc. 4). According to the Complaint, Plaintiff was arrested on October 20, 2021 on non- violent charges and his cash bond was set at $15,000. (Doc. 3, PAGEID 19). Later, Plaintiff was found not competent for trial and committed to the “Summit Health Care Center.” (Id.) Plaintiff brings a claim under 42 U.S.C. §1983 based on a violation of his civil rights. (Doc. 3). In his complaint, Plaintiff demands $1 million and asks that his criminal charges be dropped. (Id., PAGEID 20). The Magistrate Judge conducted 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). The Magistrate Judge concluded that Plaintiff’s Complaint should be dismissed with prejudice, except that Plaintiff’s claim that his charges should be dropped should be dismissed without prejudice. (Doc. 5, PAGEID 26). The Magistrate Judge explained that Plaintiff’s Complaint does not state a claim against the sole defendant, Warren County, pursuant to Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978). (Doc. 5, PAGEID 25). The Magistrate Judge explained that Plaintiff claims his bail was excessive, but Plaintiff does not identify a custom, policy, or practice of Warren County which was the “moving force” behind this alleged violation of his constitutional rights. (Id.)

As to Plaintiff’s request that the criminal charges against him be dropped, the Magistrate Judge explained that under Younger v. Harris, 401 U.S. 37, 44-45 (1971), unless there are extraordinary circumstances, a federal court must decline to interfere with pending state proceedings involving important state interests if intervention would “unduly interfere with the legitimate activities of the States.” (Doc 5. PAGEID 25). The Magistrate Judge explained that Younger abstention is warranted here, and therefore, Plaintiff’s request to drop the charges against him should be dismissed without prejudice. (Id.) In his Objections, Plaintiff does not make any specific objections to the Magistrate Judge’s R&R, but instead raises additional claims under the Administrative Procedures Act, as well as claims for violations of his right to speedy trial and violations of the Sixth, Eighth and Fourteenth Amendment. (Doc. 6, PAGEID 28, 31). II. ANALYSIS When objections to a magistrate judge’s report and recommendation are received

on a dispositive matter, the assigned district judge “must determine de novo any part of the magistrate judge’s disposition that has been properly objected to.” Fed. R. Civ. P. 72(b)(3). After review, the district judge “may accept, reject, or modify the recommended decision; receive further evidence; or return the matter to the magistrate judge with instructions.” Id.; see also 28 U.S.C. § 636(b)(1). However, “[t]he objections must be clear enough to enable the district court to discern those issues that are dispositive and contentious.” Miller v. Currie, 50 F.3d 373, 380 (6th Cir. 1995); see also Slater v. Potter, 28 F. App’x 512, 513 (6th Cir. 2002) (“The filing of vague, general, or conclusory objections does not meet the requirement of specific objections and it tantamount to a complete failure to object.”).

A plaintiff proceeding in forma pauperis does not have to incur any filing fees or court costs, leading to the lack of an economic incentive to not file any frivolous, malicious, or repetitive lawsuits. Denton v. Hernandez, 504 U.S. 25,31 (1992) (quoting Neitzke v. Williams, 490 U.S. 319, 324 (1989)). This Court can dismiss the in forma pauperis complaint if it is found that the action is frivolous or malicious. 28 U.S.C. §§1915(e)(2)(B)(i). A complaint may be frivolous if there is not a rational or arguable basis in fact or law. Neitzke, 490 U.S. at 328-29. Although detailed factual allegations are not required, there needs to be enough factual content, accepted as true, to “state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). The Court must accept allegations of facts as true except conclusory statements or mere threadbare recitations of the elements. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). However, pro se plaintiffs are “held to a less stringent standard than formal pleadings drafted by lawyers,” and their complaints must be “liberally construed.”

Erickson v. Paradus, 551 U.S. 89, 94 (2007) (per curiam) (quoting Estelle v. Gamble, 429 U.S. 97,106 (1976)). The Court now turns to Plaintiff’s claims. Liability for municipalities or counties only attaches if a custom, policy, or practice attributable to the municipality or county was the “moving force” behind the violation of a plaintiff’s constitutional rights. Heyerman v. Cty. Of Calhoun, 680 F.3d 642, 648 (6th Cir. 2012) (quoting Miller v. Sanilac Cty., 606 F.3d 240, 254-55 (6th Cir. 2010)). Therefore, a plaintiff asserting a §1983 violation against a county or municipality must identify the policy, connect the policy to the county itself, and show that the plaintiff’s particular injury was incurred because of the execution of that policy. Graham v. Cty.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
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
556 U.S. 662 (Supreme Court, 2009)
Heyerman v. County of Calhoun
680 F.3d 642 (Sixth Circuit, 2012)
Miller v. Sanilac County
606 F.3d 240 (Sixth Circuit, 2010)
Cummings v. Husted
795 F. Supp. 2d 677 (S.D. Ohio, 2011)
Sylvia James v. Hilliard Hampton
513 F. App'x 471 (Sixth Circuit, 2013)
John Doe v. Univ. of Kentucky
860 F.3d 365 (Sixth Circuit, 2017)
Miller v. Currie
50 F.3d 373 (Sixth Circuit, 1995)
Brindley v. McCullen
61 F.3d 507 (Sixth Circuit, 1995)
Callihan v. Schneider
178 F.3d 800 (Sixth Circuit, 1999)