Rodney A. Campbell v. St. Clair County Jail, et al.

Summary

The United States District Court for the Eastern District of Missouri granted Rodney A. Campbell’s application to proceed without prepaying fees and assessed a one-dollar initial partial filing fee. The court determined that the St. Clair County Jail, the State of Illinois, and potentially the Fairview Heights Police Department were not proper defendants, and that venue was improper, directing dismissal of the action without prejudice.

Holdings

1. The court granted Plaintiff's application to proceed without prepaying fees or costs and assessed an initial partial filing fee of one dollar, while recognizing that his negative inmate-account balance appeared to make him unable to pay it immediately.
2. The St. Clair County Jail and the State of Illinois were not proper defendants to the action.
3. Assuming the Fairview Heights Police Department was sufficiently named as a defendant, it also was not a proper defendant.
4. Venue was improper in the Eastern District of Missouri, providing an independent ground for dismissal without prejudice.
5. The action was dismissed without prejudice because the named defendants were improper and venue was improper.

Questions Presented

1. Whether Plaintiff should be permitted to proceed without prepaying the filing fee.
2. Whether the St. Clair County Jail and State of Illinois were proper defendants in the action.
3. Whether the Fairview Heights Police Department, assuming it was sufficiently named, was a proper defendant.
4. Whether venue was proper in the Eastern District of Missouri.
5. Whether the action should be dismissed without prejudice during statutory prisoner screening.

Disposition

dismissed