Opinion

Griffin

Court
District Court, N.D. Ohio
Filed
Oct 14, 2025
Cited by
0 cases
Authority
More cited than 35.6%

all complaints must contain either direct or inferential allegations respecting all material elements of some viable legal theory to satisfy federal notice pleading requirements

How later courts described this case

  • all complaints must contain either direct or inferential allegations respecting all material elements of some viable legal theory to satisfy federal notice pleading requirements

Written by the judges who cited it.

The opinion

11:22 am Oct 14 2025

Clerk U.S. District Court |

Northern District of Ohio

UNITED STATES DISTRICT COURT Cleveland

NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

JEWEL GRIFFIN, ) CASE NO. 1:25 CV 1953

)

Plaintiff, ) JUDGE DAN AARON POLSTER

)

vs. ) MEMORANDUM OPINION

) AND ORDER

POLICE CHIEF TODD HANSEN, )

)

Defendant. )

Pro se plaintiff Jewel Griffin filed this civil rights action against Maple Heights Police

Chief Todd Hansen, (Doc. No. 1). Plaintiff also filed an application to proceed in forma

pauperis. (Doc. No. 2). The Court grants the application, but for the following reasons,

dismisses the action.

I. Background

Plaintiff's pleading, in its entirety, states that “I am trying for 3 years to get help from

Todd concerning a human trafficking and he has ignored my case and deny me and right to

investigation by blocking the case.” (Doc. No. 1 at 4). The pleading does not include a proper

request for relief.

II. Standard of Review

Pro se pleadings are liberally construed. Boag v. MacDougall, 454 U.S. 364, 365, 102 S.

Ct. 700, 70 L. Ed. 2d 551 (1982) (per curiam); Haines v. Kerner, 404 U.S, 519, 520, 92 S. Ct.

594, 30 L. Ed. 2d 652 (1972). The district court, however, 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, 328,

109 S. Ct. 1827, 104 L. Ed. 2d 338 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990);

Sistrunk v, City of Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). 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, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007).

Under Federal Rule of Civil Procedure 8(a)(2), 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, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (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. Twombly, 550 U.S. at 555. The

plaintiff is not required to include detailed factual allegations, but he or she must provide more

than “an unadorned, the defendant unlawfully harmed me accusation.” [gbal, 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. Jd. The Court is “not bound to accept as true a legal

conclusion couched as a factual allegation.” Papasan v. Allain, 478 U.S. 265, 286, 106 S. Ct.

2932, 92 L. Ed. 2d 209 (1986).

In reviewing a complaint, the Court must construe the pleading in the light most

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

1998).

I. Discussion

The Court recognizes that pro se pleadings are held to a less stringent standard than

formal pleadings drafted by lawyers. El Bey v. Roop, 530 F.3d 407, 413 (6th Cir, 2008).

However, the “lenient treatment generally accorded to pro se litigants has limits.” Pilgrim v.

Littlefield, 92 F.3d 413, 416 (6th Cir. 1996). Liberal construction for pro se litigants does not

“abrogate basic pleading requirements.” Wells v. Brown, 891 F.2d 591, 594 (6th Cir. 1989). The

Court is not required to conjure unpleaded facts or construct claims against defendants on behalf

of a pro se plaintiff. See Bassett v. Nat’l Collegiate Ath. Ass’n, 528 F.3d 426, 437 (6th Cir.

2008). Although specific facts are not required, to meet the basic minimum notice pleading

requirements of Rule 8 of the Federal Rules of Civil Procedure, Plaintiff's complaint must give

the defendants fair notice of what the plaintiffs legal claims are and the factual grounds on

which they rest. Id.; see also Scheid v. Fanny Farmer Candy Shops, Inc., 859 F.2d 434, 437 (6th

Cir. 1988) (all complaints must contain either direct or inferential allegations respecting all

material elements of some viable legal theory to satisfy federal notice pleading requirements)

(citations omitted).

Here, Plaintiff's complaint, even liberally construed, fails to meet the most basic

pleading standard, as her pleading fails to set forth “a short and plain statement of [any] claim

showing that [Plaintiff] is entitled to relief[.]” Fed. R. Civ. P. 8(a)(2). The complaint fails to

include any discernible factual allegations. Additionally, the complaint fails to assert a

cognizable claim within the jurisdiction of this Court based on recognized legal authority, and

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the Court finds there is no cause of action readily identifiable in the complaint. Plaintiff's

inclusion of various federal criminal statutes as a basis for federal jurisdiction does not satisfy

pleading requirements. Finally, the complaint fails to connect any alleged occurrence to any

specific, cognizable injury. The complaint does not satisfy the minimum pleading requirements

of Rule 8 and is therefore dismissed on this basis.

IV. Conclusion

Accordingly, the Court grants Plaintiff’s application to proceed in forma pauperis (Doc.

No. 2). And for the foregoing reasons, the Court dismisses this action pursuant to 28 U.S.C. §

1915(e). Further, 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. fo )

IT IS SO ORDERED. ND ip

/ a Fe

DANAARONPOLSTER

UNITED STATES DISTRICT JUDGE

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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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