Maurice Campbell v. Erin Halbert et al.

Summary

The United States District Court for the Eastern District of Missouri grants Maurice Campbell leave to proceed in forma pauperis but dismisses his 42 U.S.C. § 1983 complaint without prejudice under 28 U.S.C. § 1915(e)(2)(B). The court concludes that the claims against state entities and officials fail because of sovereign immunity, lack of municipal-policy allegations, insufficient personal involvement, and failure to plead a plausible constitutional violation; it also denies appointment of counsel as moot.

Holdings

1. The Missouri Board of Probation and Parole and the ERDCC Records Office are state entities and are not persons subject to suit under 42 U.S.C. § 1983. Claims against them were properly dismissed under 28 U.S.C. § 1915(e)(2)(B).
2. The official-capacity claims failed because the complaint did not identify a municipal policy, widespread custom, or deliberately indifferent failure to train or supervise causing the alleged injuries, and the claims against state parole and correctional officials were unavailable or immune. The requested prospective injunction also failed because the complaint did not plausibly allege an ongoing federal violation traceable to a named official with authority to provide relief.
3. The individual-capacity claims failed because Campbell did not plead defendant-specific facts establishing each defendant's personal involvement in, or causal connection to, a constitutional deprivation.
4. To the extent Campbell challenged parole-related decision-making itself, the relevant functions were quasi-judicial and protected by absolute immunity.
5. The complaint was dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B), and the motion for appointment of counsel was denied as moot.

Questions Presented

1. Whether the Missouri Board of Probation and Parole and the ERDCC Records Office were suable persons under 42 U.S.C. § 1983.
2. Whether claims against the state entities and governmental employees in their official capacities were barred by sovereign immunity or failed to satisfy the requirements for official-capacity liability.
3. Whether the complaint plausibly alleged personal involvement and a causal connection between each individual defendant's conduct and a constitutional violation.
4. Whether parole-related decision-making by the defendants was protected by absolute quasi-judicial immunity.
5. Whether the complaint should be dismissed under 28 U.S.C. § 1915(e)(2)(B).

Disposition

dismissed