Wyley v. Cuyahoga County

CourtDistrict Court, N.D. Ohio
DecidedJune 4, 2025
Docket1:25-cv-00230
StatusUnknown

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

Bluebook
Wyley v. Cuyahoga County, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION ASIA WYLEY, ) CASE NO. 1:25-CV-00230 ) Plaintiff, ) JUDGE BRIDGET MEEHAN BRENNAN ) v. ) ) CUYAHOGA COUNTY, ) OPINION AND ORDER ) Defendant. ) Plaintiff Asia Wyley (“Wyley”) initiated this action pro se to challenge her arrest, detention in the Cuyahoga County Corrections Center, and criminal conviction. (Doc. 1.) For the reasons below, this case is DISMISSED. Wyley’s application to proceed in forma pauperis (Doc. 2) is GRANTED. I. BACKGROUND The complaint contains few factual allegations. (See Doc. 1.) Wyley states that employees of Cuyahoga County discriminated against her after being notified that she has disabilities. (Id. at 2.)1 Wyley does not specify what disabilities she has or which disabilities she communicated to Cuyahoga County employees. (See id.) She states these employees “prevented [her] from seeking proper disability accommodations” while they held her in a cell “completely naked without access to sufficient, water, food, [and] hygienic facilities,” including a shower or feminine hygiene products. (Id. at 3.) The complaint does not allege the date, reason, or length of her detention. Wyley alleges Cuyahoga County employees violated her constitutional rights in 1 For ease and consistency, record citations are to the electronically stamped CM/ECF document and PageID# rather than any internal pagination. retaliation for information she had about Cuyahoga County officials. (Id.) Wyley further asserts that Cuyahoga County “fabricated information against [her] and refused to allow [her] to access information that could prove” her innocence. (Id.) As a result, Wyley alleges she was “illegally arrested and then wrongfully convicted” of a crime she did not commit. (Id.) The complaint does not specify what information Cuyahoga County fabricated or the charges Wyley faced. Wyley lists claims under the First, Second, Fourth, Fifth, Sixth, Eighth, and Fourteenth Amendments, as well as the Americans with Disabilities Act (“ADA”), 4 U.S.C. §§ 12112 et seq. (See id. at 2.) Other than listing these amendments and statute, Wyley provides no further allegations in support of her claims. (Id.) Her complaint seeks $111,000,000,000.00 in damages and other injunctive relief. (Id. at 3-7.)

Wyley did not pay the filing fee for this case, but instead filed motion to proceed in forma pauperis. (Doc. 2.) Because Wyley represents that she has no assets and no income, her motion to proceed in forma pauperis is GRANTED. II. LEGAL STANDARD Although pro se pleadings are liberally construed, Boag v. MacDougall, 454 U.S. 364, 365 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520 (1972), the Court must dismiss an in forma pauperis action under 28 U.S.C. § 1915(e) if it fails to state a claim upon which relief can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989); Sistrunk v. City of Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an

arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are clearly baseless. Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the Complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the complaint are true. Bell Atl. Corp., 550 U.S. at 555. A plaintiff is not required to include detailed factual allegations, but must provide more than “an unadorned, the-Defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. In reviewing a complaint, the Court must construe the pleading in the light most favorable to the plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.1998).

III. ANALYSIS The complaint does not rise above the speculative level to state a plausible claim for relief. Based on the information Wyley provided, the Court is left to guess at critical information needed to state a claim. For instance, Wyley has not alleged what condition qualifies as a disability, how long she was held in a cell, the circumstances of her detention, the role Cuyahoga County employees played in creating the conditions of her detention, or what information these employees fabricated. Without this basic information, the Court cannot find plausibility in the complaint. See Bell Atl. Corp., 550 U.S. at 564. Wyley does not explain why she believes Cuyahoga County violated her First, Second,

Fourth, Fifth, or Sixth Amendment rights. Nor does she explain how Cuyahoga County violated her rights under the ADA. To meet the minimum notice pleading requirements of Rule 8 of the Federal Rules of Civil Procedure, the complaint must give the defendants fair notice of what the plaintiff’s legal claims are and the factual grounds upon which they rest. Bassett v. Nat’l Collegiate Athletic Ass’n, 528 F.3d 426, 437 (6th Cir. 2008). The complaint does not contain sufficient facts to meet this basic pleading requirement. See Fed. R. Civ. P. 8; Morgan v. Church’s Fried Chicken, 829 F.2d 10, 12 (6th Cir. 1987) (legal conclusions alone are not enough to present a valid claim, and court is not required to accept unwarranted factual inferences). Separately, Wyley seeks billions of dollars in damages for constitutional violations. (See Doc. 1 at 2.) But because “[t]he Constitution does not directly provide for damages,” Wyley must proceed under “one of the statutes authorizing damages for constitutional violations.” Sanders v. Prentice-Hall Corp. Sys., 178 F.3d 1296 (Table), 1999 WL 115517, at *2 (6th Cir. 1999). Construing the complaint in the light most favorable to Wyley, the Court will treat her claims as arising under 42 U.S.C. § 1983. “The purpose of § 1983 is to deter state actors from

using the badge of their authority to deprive individuals of their federally guaranteed rights and to provide relief to victims of that deterrence fails.” Wyatt v. Cole, 504 U.S. 158 (1992).

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Boag v. MacDougall
454 U.S. 364 (Supreme Court, 1982)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Wyatt v. Cole
504 U.S. 158 (Supreme Court, 1992)
Blessing v. Freestone
520 U.S. 329 (Supreme Court, 1997)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Carolyn Morgan v. Church's Fried Chicken
829 F.2d 10 (Sixth Circuit, 1987)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Neil Morgan v. Fairfield Cty., Ohio
903 F.3d 553 (Sixth Circuit, 2018)
Tammy Brawner v. Scott Cnty., Tenn.
14 F.4th 585 (Sixth Circuit, 2021)

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Bluebook (online)
Wyley v. Cuyahoga County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wyley-v-cuyahoga-county-ohnd-2025.