Lewis v. Brumfield

Background

Daronta T. Lewis, proceeding without a lawyer, filed a 68-page complaint against Michael Brumfield and other defendants. Lewis alleged several unrelated claims involving former jailors at West County Detention Center, including excessive force, First Amendment retaliation, violations of the Americans with Disabilities Act, an unclean cell, sexual assault, unsafe transportation, and denial of access to the courts.

Court’s analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires review of a prisoner’s complaint against a governmental entity or officer. The court must dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also explained that a claim under 42 U.S.C. § 1983 requires an alleged violation of a federal right by someone acting under state law.

The court focused on the rule governing joinder of claims and defendants. That rule generally requires claims brought in one action to arise from the same transaction or related transactions and to share a common legal or factual question. The court held that Lewis’s unrelated claims could not all proceed in the same complaint. It instructed him to choose a claim, such as excessive force, denial of court access, or denial of appropriate housing, and include only claims closely related to the facts of that chosen claim.

Rulings on the motions

The court dismissed the complaint with leave to file an amended complaint on or before January 25, 2021. The amended complaint had to use the caption and case number in the order, state “FIRST AMENDED COMPLAINT” on its first page, use the court’s form, include every claim and defendant Lewis wished to pursue, and generally be no longer than 10 pages. The court said failure to comply could lead to dismissal under Federal Rule of Civil Procedure 41(b) for failure to prosecute.

The court denied as moot Lewis’s motion seeking to prevent the West County Detention Facility from interfering with his access to the courts and his motion seeking an order stopping interference with his mail, because he was no longer housed there. The court granted his motion for a complaint form. It denied as premature his request for a copy of the complaint, while stating that he could request a copy after filing a compliant amended complaint. The court also granted his motion for copies of all docket documents.

The order addressed pleading and filing requirements; it did not decide the merits of Lewis’s underlying claims.