Brown v. Federal Bureau of Investigation

Background

Shawn C. Brown sued numerous defendants, including the Federal Bureau of Investigation, the Central Intelligence Agency, the U.S. Department of Justice, local government departments and offices, hospitals, private entities, and individuals. His complaint identified “Negligence” and “Civil Rights 1983” as the asserted claims. Brown did not pay the filing fee and instead applied to proceed without paying it.

The court determined that Brown qualified financially for that status but explained that the court must deny the application and dismiss an action if the complaint fails to state a claim for which relief may be granted. The court reviewed the complaint under 28 U.S.C. § 1915(e)(2)(B), the statute governing screening of qualifying fee-waiver cases.

Reasons for dismissal

The court found that the filing was barely a complaint. It contained a lengthy list of defendants but no factual allegations, while an attached exhibit included medical records, state-court records, and many pages of handwritten notes. Because the allegations were spread across multiple documents, the court could not determine which specific allegations were being asserted against which defendants or what facts supported the claims.

The court also held that the complaint failed Federal Rule of Civil Procedure 20(a)(2), which governs joining multiple defendants in one lawsuit. The materials described many apparently unrelated events, and the court identified no obvious connection between claims against the Federal Bureau of Investigation and claims against the Saint Louis County Public Defender’s Office.

As to the claims under 42 U.S.C. § 1983, the court stated that only state actors can be sued under that statute and that some named defendants were not state actors or were entities that could not be sued under § 1983. The court further held that Brown had not pleaded plausible facts from which a reasonable factfinder could conclude that any defendant violated his federal constitutional rights.

Brown’s negligence claim arose under state law. The court stated that it could hear that claim under its original jurisdiction only if the parties were citizens of different states, and Brown had not pleaded that such diversity existed. The court also stated that it was required not to exercise supplemental jurisdiction over state-law claims after dismissing all federal-law claims before trial.

Disposition

The court dismissed the matter without prejudice in its entirety under 28 U.S.C. § 1915(e)(2)(B). It denied Brown’s application to proceed without paying the filing fee.

The court also addressed Brown’s filing of twelve lawsuits in the District of Minnesota in a little over a week. It restricted Brown from initiating new litigation in that district unless he was represented by counsel or obtained authorization from a judicial officer of the district. The restriction lasted until July 5, 2023. Judge Katherine Menendez ordered judgment to be entered accordingly.