Woodson v. Eravi

CourtDistrict Court, E.D. Missouri
DecidedJune 17, 2025
Docket2:25-cv-00017
StatusUnknown

This text of Woodson v. Eravi (Woodson v. Eravi) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Woodson v. Eravi, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

JAMES WOODSON, ) ) Plaintiff, ) ) v. ) Case No. 2:25-cv-00017-JSD ) NELSON D. ERAVI, et al., ) ) Defendants. )

MEMORANDUM AND ORDER

Self-represented Plaintiff James Woodson brings this action under 42 U.S.C. § 1983 for alleged violations of his civil rights. The matter is now before the Court upon multiple motions filed by Plaintiff. First, Plaintiff seeks leave to proceed in forma pauperis, or without prepayment of the required filing fees and costs. ECF No. 5. Based on a review of the financial information submitted in support, the Court will grant the motion and order no further payment. Second, Plaintiff filed a motion for an extension of time to comply with the Court’s “Order Dated February 14, 2025.” ECF No. 8. Because the Court did not issue an Order in this matter on February 14, 2025, and the Court cannot determine that there is any outstanding order that Plaintiff has failed to comply with, this motion will be denied as moot. Third, Plaintiff filed a motion for prohibition of retaliation in which he seeks an order prohibiting retaliation against him, without any argument or legal rationale. ECF No. 3. However, because Plaintiff is now proceeding in forma pauperis, the Court must review his pleadings under 28 U.S.C. § 1915. Based on such review, the Court will dismiss this case for failure to state a claim upon which relief may be granted. See 28 U.S.C. § 1915(e)(2)(B). Since this case is being dismissed, Plaintiff’s unsupported motion for prohibition will be denied as moot.

Motion to Proceed In Forma Pauperis (ECF No. 5) Pursuant to 28 U.S.C. § 1915(b)(1), a prisoner bringing a civil action in forma pauperis is required to pay the full amount of the filing fee. If the prisoner has insufficient funds in his or her prison account to pay the entire fee, the Court must assess and, when funds exist, collect an initial partial filing fee. Plaintiff here is a convicted and sentenced state court prisoner. ECF No. 1 at 2.

He filed his Complaint on February 10, 2025, without paying the required filing fee or filing a motion to proceed in forma pauperis. As a result, the Court issued an Order on February 11, 2025, directing Plaintiff to either pay the $405 filing fee or submit a motion to proceed in forma pauperis. ECF No. 4. On February 13, 2025, Plaintiff filed a motion to proceed in forma pauperis with a certified inmate account statement. ECF No. 5. A

couple of weeks later, Plaintiff paid $350 towards his filing fee. ECF No. 6. Over two months have passed since the filing fee payment was made and Plaintiff has not withdrawn his motion to proceed in forma pauperis. Proceeding in forma pauperis confers benefits on a litigant aside from payment of the filing fee in installments, including reduced copy rates and service on defendants by the U.S.

Marshal’s Service.1 Because of these additional benefits and because Plaintiff has not withdrawn his motion, the Court will assume that Plaintiff still seeks such status in this

1 The Court notes that Plaintiff did attach an exhibit to his Complaint requesting summons be served by the U.S. Marshals. See ECF No. 1-1 at 1. case.2 After review of the financial information submitted in support of the motion, the Court will grant Plaintiffs’ motion to proceed in forma pauperis. No further filing fee payments are required.3

The Complaint (ECF No. 1) Plaintiff is incarcerated at Moberly Correctional Center (MCC), a Missouri Department of Corrections (MDOC) facility. ECF No. 1 at 2. He brings this action under 42 U.S.C. § 1983, against four defendants associated with MCC: (1) Nelson Eravi (correctional officer); (2) MDOC Director; (3) MCC Warden; and (4) Unknown Bucker

(investigating officer). Id. at 1-3. Plaintiff appears to be naming the MDOC Director in his official capacity only, but he names the other three defendants in both their official and individual capacities. Id. (listing both capacities under all defendants except MDOC Director where it states only “OFFICIAL CAPACITY”). Plaintiff alleges that his rights under the Fifth, Eighth, and Fourteenth

Amendments have been violated by the MDOC’s use of fraudulent drug field tests at MCC, which have resulted in false positives and caused prisoners to be unjustifiably

2 In addition, Plaintiff’s recently filed motion suggests that he still seeks in forma pauperis status when he states that he “awaits this Court’s order determining financial status regarding indigency.” ECF No. 8 at 1.

3 The fee for bringing a civil action in this Court is $405, which includes a statutory filing fee of $350 and an administrative fee of $55. See 28 U.S.C. § 1914(a) (“The clerk of each district court shall require the parties instituting any civil action, suit or proceeding in such court, whether by original process, removal, or otherwise, to pay a filing fee of $350”); 28 U.S.C. § 1914(b) (“The clerk shall collect from the parties such additional fees only as are prescribed by the Judicial Conference of the United States”). Effective December 1, 2023, the Judicial Conference added a $55.00 administrative fee to the statutory fee for filing a civil action in district court. See Par. 14 of the Judicial Conference Schedule of Fees, District Court Miscellaneous Fee Schedule (issued in accordance with 28 U.S.C. § 1914) (effective on Dec. 1, 2023). The Judicial Conference expressly provided, however, that the additional $55.00 “fee does not apply to applications for a writ of habeas corpus or to persons granted in forma pauperis status under 28 U.S.C. § 1915.” Id. As such, since Plaintiff has already paid the statutory filing fee of $350, and the Court is granting his motion to proceed in forma pauperis, no further payment is due. punished with false conduct violations. Id. at 5. According to Plaintiff, these unwarranted punishments result in cruel and unusual punishment and violations of due

process. Id. at 6. The facts alleged by Plaintiff are as follows. In March 2024, defendant Eravi confiscated a piece of paper wrapped in tape from Plaintiff’s left coat pocket. The paper was “field tested” (by an officer not named as a defendant in this matter) and was found to be positive for synthetic marijuana. Id. at 4 & 6. As a result of this test result, Plaintiff received a conduct violation from Eravi for possession of a controlled substance.

Plaintiff was recommended to receive sanctions of ten (10) days in disciplinary segregation, no visits for thirty (30) days, and referral to the review board. Id. at 4. Plaintiff does not state what punishment he eventually received. Plaintiff asserts multiple claims regarding this allegedly false conduct violation. First, Plaintiff alleges that defendant Eravi could not “truthfully” write him up for a

violation since Eravi did not “observe himself” the testing of the substance by a different officer. Id. at 6. Plaintiff argues that this violates his due process and equal protection rights. Id. at 7.

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Woodson v. Eravi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/woodson-v-eravi-moed-2025.