Opinion

Deadwiley v. State of Ohio

Court
District Court, N.D. Ohio
Filed
Jul 10, 2025
Cited by
0 cases
Authority
More cited than 37.5%

holding the appropriate statute of limitations for § 1983 civil rights actions arising in Ohio is the two-year limitation contained in Ohio Rev. Code § 2305.10

How later courts described this case

  • holding the appropriate statute of limitations for § 1983 civil rights actions arising in Ohio is the two-year limitation contained in Ohio Rev. Code § 2305.10

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

JAMES DEADWILEY, ) CASE NO. 1:25-CV-1110

)

Plaintiff, ) JUDGE CHARLES E. FLEMING

)

vs. )

) MEMORANDUM OPINION AND

STATE OF OHIO, et al., ) ORDER

)

Defendants. )

I. INTRODUCTION

Pro se Plaintiff James Deadwiley brings this action under 42 U.S.C. § 1983 against the

State of Ohio, Cuyahoga County, the Ohio Department of Rehabilitation and Corrections

(“ODRC”), and the Cuyahoga County Sheriff, claiming he was denied a speedy trial. (ECF No.

1). He asks this Court to order the State of Ohio to give him a new trial. (Id. at PageID #5).

II. BACKGROUND

Plaintiff was arrested on July 22, 2017 and charged in the Cuyahoga County Court of

Common Pleas with two counts of felonious assault, two counts of domestic violence, two counts

of endangering children, and one count of having a weapon under disability. See State of Ohio v.

Deadwiley, No. CR-17-619876-A (Cuyahoga Cty Comm. Pl. Ct. Sep. 13, 2019). Four months

later, on November 1, 2017, Plaintiff was indicted on charges of rape, attempted rape, and

kidnapping with sexually violent offender specifications for an incident that occurred on May 25,

2014. See State of Ohio v. Deadwiley, No. CR-17-622444-A (Cuyahoga Cty Comm. Pl. Ct. Apr.

2, 2019). Plaintiff was tried on the rape, attempted rape, and kidnapping charges on February 8,

2019. Id. He was found guilty on all charges on February 12, 2019, and was sentenced on April

2, 2019, to an aggregate total of fifteen years to life in prison. Id. He was tried on the felonious

assault, domestic violence, child endangering, and having a weapon under disability charges on

September 12, 2019. State of Ohio v. Deadwiley, No. CR-17-619876-A (Cuyahoga Cty Comm.

Pl. Ct. Sep. 13, 2019). He was found not guilty of those charges. Id. Plaintiff filed a motion for

jail time credit on June 12, 2020. State of Ohio v. Deadwiley, No. CR-17-622444-A (Cuyahoga

Cty Comm. Pl. Ct. Apr. 2, 2019). The trial court granted his motion and credited 763 days to his

sentence for time he spent in jail awaiting trial and transport to prison. Id.

Plaintiff filed this action on May 29, 2025, claiming he was denied a speedy trial and asking

this Court to order the State of Ohio to give him a new trial. (ECF No. 1, PageID #5). He contends

he was held in jail for three years while he was awaiting trial. (Id.). It appears from the Cuyahoga

County Common Pleas Court docket that he was indicted on the rape, attempted rape, and

kidnapping charges on November 1, 2017 and was convicted on February 12, 2019, which suggests

he was held as a pretrial detainee in Case No. CR-17-622444-A for 1 year, 3 months, and 11 days.

III. STANDARD OF REVIEW

Although pro se pleadings are liberally construed, Boag v. MacDougall, 454 U.S. 364, 365

(1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520 (1972), the Court is required to dismiss

an in forma pauperis action under 28 U.S.C. § 1915(e) if it fails to state a claim upon which relief

can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319

(1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990). A claim lacks an arguable basis in law

or fact when it is premised on an indisputably meritless legal theory or when the factual contentions

are clearly baseless. Neitzke, 490 U.S. at 327.

A cause of action fails to state a claim upon which relief may be granted when it lacks

plausibility in the complaint. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A pleading

must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.”

Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009). The factual allegations in the pleading must be

sufficient to raise the right to relief above the speculative level on the assumption that all the

allegations in the complaint are true. Bell Atl. Corp., 550 U.S. at 555. Plaintiff is not required to

include detailed factual allegations, but must provide more than “an unadorned, the-defendant-

unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal

conclusions or a simple recitation of the elements of a cause of action will not meet this pleading

standard. Id. In reviewing a complaint, the Court must construe the pleadings in the light most

favorable to the Plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir. 1998).

IV. DISCUSSION

Upon review, the Court finds that Plaintiff’s Complaint must be dismissed pursuant to

§ 1915(e) because it fails to state a plausible federal civil rights claim upon which he may be

granted relief. Beginning with Preiser v. Rodriguez, 411 U.S. 475 (1973), federal courts have

drawn careful lines between relief properly considered in a habeas corpus action and relief that is

proper to a civil rights action under 42 U.S.C. § 1983. The Supreme Court held in Preiser that state

prisoners who seek to challenge their convictions or their sentences, as Plaintiff does here, must

seek habeas corpus relief under 28 U.S.C. § 2254 rather than relief in a civil rights action under

§ 1983. See Id. at 500 (“[W]e hold today that when a state prisoner is challenging the very fact or

duration of his physical imprisonment, and the relief he seeks is a determination that he is entitled

to immediate release or a speedier release from that imprisonment, his sole federal remedy is a

writ of habeas corpus.”). Because Plaintiff challenges the validity of a state criminal conviction

and seeks a new trial, his claim is not cognizable in a civil rights action. Accordingly, his complaint

fails to state a plausible claim upon which he may be granted relief.

Further, even if Plaintiff’s complaint asserted a cognizable civil rights claim, his action is

time-barred. His complaint challenges a 2019 conviction. A civil rights complaint under § 1983

is governed by Ohio’s two-year statute of limitations. Browning v. Pendleton, 869 F.2d 989, 992

(6th Cir. 1989) (holding the appropriate statute of limitations for § 1983 civil rights actions arising

in Ohio is the two-year limitation contained in Ohio Rev. Code § 2305.10). Plaintiff's trial began

on February 8, 2019 and he was convicted on February 12, 2019. See State of Ohio v. Deadwiley,

No. CR-17-622444-A (Cuyahoga Cty Comm. Pl. Ct. Apr. 2, 2019). He filed this action on May

29, 2025, more than six years after his conviction. (ECF No. 1). The limitation period has run,

and this action is untimely.

V. CONCLUSION

Accordingly, this action is DISMISSED pursuant to 28 U.S.C. § 1915(e). The Court

CERTIFIES, pursuant to 28 U.S.C. § 1915(a)(3), that an appeal from this decision could not be

taken in good faith.

IT IS SO ORDERED.

Date: July 10, 2025 Oadby Suse

CHARLES E.FLEMING ts

UNITED STATES DISTRICT JUDGE

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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