Cleaves v. Sopha

Background

Trea Cleaves filed the case without a lawyer. The operative pleading was her second amended complaint, which was 383 pages long and named at least 20 defendants. The court said that, to the extent the claims could be understood, they appeared to include claims described as “marriage as RICO crime scene” and “domestic terrorism.”

A magistrate judge allowed Cleaves to proceed without paying the filing fee and screened her initial complaint under 28 U.S.C. § 1915(e). The magistrate judge found, among other problems, that the complaint did not comply with Rule 8 of the Federal Rules of Civil Procedure. Rule 8 requires a complaint to include a short and plain statement of the claim. Cleaves received opportunities to file amended complaints, and the magistrate judge screened the second amended complaint as well.

Court’s Analysis

The magistrate judge found that the second amended complaint still failed to satisfy Rule 8 because it was not a short and plain statement that would give defendants fair notice of the claims. The screening order also noted that many allegations concerned events from the 1980s through 2008, more than a decade before the original complaint was filed in December 2022, and therefore appeared on their face to raise statute-of-limitations problems.

Cleaves responded to the recommendation by filing an administrative motion concerning the deadline for opposing dismissal. The court noted that the motion did not identify a new deadline and included a lengthy statement of objections that was difficult to follow. After independently reviewing the docket, the court agreed that the second amended complaint was inadequate under Rule 8. It concluded that another amendment opportunity would be futile and was not required.

Disposition

The court adopted the magistrate judge’s recommendation and dismissed the case with prejudice. The order was issued by United States District Judge James Donato on December 14, 2023.