Opinion

Brown v. Key

Court
District Court, E.D. Arkansas
Filed
Oct 3, 2025
Cited by
0 cases
Authority
More cited than 35.1%

“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”

How later courts described this case

  • “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”

Written by the judges who cited it.

The opinion

IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF ARKANSAS

NORTHERN DIVISION

EDWARD LEE BROWN PLAINTIFF

V. Case No. 3:25-CV-00208-JM

NATHANIAL KEY DEFENDANT

ORDER

Plaintiff Edward Lee Brown’s motion to proceed in forma pauperis (Doc. 1) is granted. He

reports limited income. See Martin-Trigona v. Stewart, 691 F.2d 856, 857 (8th Cir. 1982) (per

curiam) (complaint can be filed if plaintiff qualifies by economic status under 28 U.S.C.

§ 1915(a)).

The law requires that I screen the Complaint. 28 U.S.C. § 1915(e)(2). “A pro se plaintiff

must set forth enough factual allegations to ‘nudge [ ] their claims across the line from conceivable

to plausible,’ or ‘their complaint must be dismissed’ for failing to state a claim upon which relief

can be granted.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 569-70 (2007); see also Aschroft

v. Iqbal, 556 U.S. 662, 678 (2009) (“A claim has facial plausibility when the plaintiff pleads factual

content that allows the court to draw the reasonable inference that the defendant is liable for the

misconduct alleged.”). Regardless of whether a plaintiff is represented or is appearing pro se, the

plaintiff’s complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent,

780 F.2d 1334, 1337 (8th Cir. 1985).

Brown’s Complaint is difficult to follow. (Doc. 2). Brown does not use a standard

complaint form, has loosely narrated events, and has written his thoughts on various documents.

Basically, there appears to have been some sort of an interaction between him and his neighbor

Nathanial Key over Brown’s dogs barking. Police were called and an incident report was issued.

Brown alleges a violation of his “liberty rights,” mentions his race, and names various police

officers. It is not clear, however, who Brown intends to sue (Key or the responding officers), the

cause of action (e.g., harassment, civil rights violation), or what relief Brown is requesting.

Brown will be given 30 days from this Order to file an amended complaint curing the

deficiencies identified in this order. If he chooses not to amend his complaint, or if his amended

complaint does not cure the problems with his current complaint, then the Court will dismiss it

without prejudice. Brown is warned that his amended complaint will take the place of his current

complaint. That means that he must include any and all factual allegations in his amended

complaint that he wants the Court to consider. The Court directs the Clerk to mail Brown a blank

§1983 complaint and a blank civil complaint. Brown need only return one completed complaint

depending on the cause of action he intended to bring.

IT IS SO ORDERED this 3? day of October, 2025.

OO crn

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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