Armstrong v. St. Louis County Sheriff's Dept.

Background

Seth A. Armstrong filed a complaint against the St. Louis County Sheriff’s Department and identified “State of Minnesota – any and all involved” as defendants in his application to proceed without prepaying fees or costs. Armstrong alleged that the Sheriff’s Department had targeted and harassed him for the previous two years and that he had been charged with criminal offenses that were later dropped. The complaint did not expressly identify a cause of action.

Screening standard

Because Armstrong sought to proceed without paying the filing fee, the court reviewed the complaint under 28 U.S.C. § 1915(e). The court stated that a complaint must include enough factual allegations to state a plausible claim for relief. Although courts read complaints filed without a lawyer liberally, they are not required to create claims that the complaint does not clearly raise.

Court’s analysis

The court considered whether the allegations could support a claim under 42 U.S.C. § 1983, the federal law that allows a person to seek relief for a constitutional violation committed by someone acting under state authority. It concluded that the St. Louis County Sheriff’s Department is not a legal “person” subject to suit under Section 1983. The court also stated that the State of Minnesota is not a person subject to Section 1983 liability and that the Eleventh Amendment bars Section 1983 claims against the state. Armstrong did not specifically identify any state officials as defendants or allege facts showing that a state official violated his constitutional rights.

Disposition

The court dismissed Armstrong’s complaint without prejudice for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). It denied Armstrong’s application to proceed without prepaying fees or costs as moot. Judge Jeffrey M. Bryan directed that judgment be entered accordingly.