Canada v. Stehr

Background

Shawn Canada filed a five-page complaint without a lawyer and applied to proceed without paying the filing fee. The defendants were Dan Stehr, Dan Sepeda, Damascus Way staff members, Robyn Wood, Olmsted County of Corrections, Doug Nelson, Alex Bunger, Paul Flessner, and Sarah Sommer.

The complaint did not contain a factual narrative. Instead, Canada listed at least 15 federal statutes, the Fifth Amendment, and common-law theories including slander, defamation, and entrapment. He attached a one-page “Damascus Way Resident Discharge Summary,” which stated that he was admitted to the Damascus Way Re-Entry Center on November 6, 2019, and discharged on April 17, 2020, for failing to comply with health and safety policies related to the COVID-19 pandemic. The opinion states that the complaint otherwise provided no information about the events or actions giving rise to the lawsuit.

Legal standard

Because Canada was incarcerated, the court reviewed the complaint under 28 U.S.C. § 1915A(b). That statute requires dismissal of a prisoner’s complaint, in whole or in part, if it fails to state a legally sufficient claim.

The court applied Federal Rule of Civil Procedure 8(a)(2), which requires a complaint to provide a short and plain statement showing that the plaintiff is entitled to relief. The court explained that a complaint must give defendants fair notice of the claims and the grounds supporting them. Although courts read complaints filed without a lawyer broadly, they are not required to assume facts that the plaintiff did not allege.

Court’s analysis

The court concluded that Canada’s complaint did not satisfy Rule 8(a)(2). It did not identify the factual basis for his claims or connect the defendants’ conduct to the discharge from Damascus Way. The court also found no connection between the discharge summary and the statutes and legal theories Canada listed.

As one example, Canada cited 18 U.S.C. § 1512, a criminal statute concerning tampering with a witness, victim, or informant. The court found no apparent connection between that statute and Canada’s discharge. It also held that, even if such a connection existed, private citizens cannot bring criminal obstruction-of-justice charges under § 1512 because the statute does not create a private right to sue.

The court determined that Canada had likewise failed to state a claim under each of the other 14 statutes he cited because he did not associate those statutes with facts or conduct by the defendants. The court therefore concluded that the complaint failed to state a claim.

Disposition

The court DISMISSED Canada’s complaint for failure to state a claim under 28 U.S.C. § 1915A(b)(1). It also DENIED Canada’s motion to proceed without paying the filing fee as moot. The order directed that judgment be entered accordingly. The opinion does not state whether the dismissal was with or without prejudice.