Travis Scott McCall v. Isaac McKenzie, Juan Olalde, Unknown Officer

Summary

This Report and Recommendation addresses a pro se, in forma pauperis 42 U.S.C. § 1983 action brought by Travis Scott McCall against law-enforcement defendants arising from his September 18, 2025 arrest in Greenville, South Carolina. The magistrate judge recommends dismissal without leave to amend and without issuance or service of process based on duplicative litigation, Younger abstention, failure to allege personal wrongdoing by the named defendants, and failure to state claims for unlawful arrest, malicious prosecution, or excessive force.

Holdings

1. A district court may dismiss an in forma pauperis prisoner complaint at screening if it is frivolous or malicious, fails to state a claim, or seeks monetary relief from an immune defendant.
2. Federal courts should abstain from interfering with ongoing state criminal proceedings when the proceedings implicate important state interests and provide an adequate opportunity to raise federal constitutional claims, absent extraordinary circumstances.
3. A district court may dismiss a repetitive or duplicative lawsuit as frivolous under 28 U.S.C. § 1915 when the parties, issues, and available relief do not significantly differ from an earlier action.
4. A complaint that names defendants in the caption but alleges no specific conduct by them fails to state a plausible § 1983 claim.
5. The complaint failed to state Fourth Amendment claims for unlawful arrest or false imprisonment because McCall did not allege that he was seized without probable cause, and it failed to state a malicious-prosecution claim because the criminal proceedings had not ended without a conviction.

Questions Presented

1. Whether the complaint should be screened and summarily dismissed under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A.
2. Whether Younger abstention barred federal relief that would interfere with McCall's pending state criminal proceedings.
3. Whether the action was duplicative of McCall's other federal cases and therefore frivolous.
4. Whether McCall stated a plausible § 1983 claim against the defendants named in this action.
5. Whether McCall adequately alleged unlawful arrest, false imprisonment, malicious prosecution, excessive force, or other constitutional claims.

Disposition

other