Summary
The United States District Court for the Middle District of Tennessee grants Gregory Ryan Webb’s application to proceed in forma pauperis but dismisses his 42 U.S.C. § 1983 action against Cumberland County Sheriff Casey Cox with prejudice. The court concludes that the claims are barred by Tennessee’s one-year statute of limitations and, alternatively, fail to state a claim because there is no constitutional right to a criminal investigation and no alleged municipal policy or custom supporting official-capacity liability. The court denies as moot Plaintiff’s motion and supporting memorandum and declines to certify an appeal for in forma pauperis status.
Topics
Practice areas
Questions Presented
- Whether Webb's § 1983 claims were barred by the applicable one-year statute of limitations.
- Whether the complaint stated a § 1983 claim against Sheriff Cox in his individual capacity based on the alleged failure to investigate Webb's allegations.
- Whether the complaint stated an official-capacity or municipal-liability claim against Sheriff Cox without alleging a qualifying Cumberland County policy, practice, or custom.
- Whether Webb was entitled to proceed in forma pauperis.
Holdings
- The claims were barred by the applicable one-year statute of limitations because the alleged precipitating events occurred primarily in 2021 and 2022, more than one year before the complaint was filed on October 7, 2025.
- The complaint failed to state a claim against Sheriff Cox in his individual capacity because Webb had no judicially cognizable interest in the investigation or prosecution of another person and Cox owed Webb no constitutional duty to investigate the allegations Webb brought to his attention.
- The complaint failed to state an official-capacity claim because it did not allege that a Cumberland County policy, practice, or custom caused a deprivation of a federal right.
- The IFP application was granted because Webb's financial information showed that he was unable to pay the filing fee without undue hardship.
Key quotations
“The statute of limitations for a Section 1983 action is the “state statute of limitations applicable to personal injury actions under the law of the state in which the § 1983 claims arise.”” (Section II.B)
“private citizens lack any “judicially cognizable interest” in the criminal investigation or prosecution of another.” (Section II.B)
“Based on the foregoing, this pro se action filed by Plaintiff Gregory Ryan Webb is DISMISSED WITH PREJUDICE as filed outside the governing one-year statute of limitations or, alternatively, for failure to state a claim upon which relief may be granted under Section 1983.” (Conclusion)
Factual background
Webb alleged that he sent Sheriff Casey Cox statements in 2025 concerning events from 2021 and 2022, including an alleged kidnapping of Webb's son and related conduct involving sheriff's department deputies and members of Webb's church congregation. Webb claimed that Cox intentionally failed to investigate the information and sought more than $126,000 in litigation expenses and over $1 billion in punitive damages. The complaint also asserted that Webb had recently recovered memories allegedly lost through trauma or amnesia.
Procedural history
Webb filed his complaint on October 7, 2025, alleging that Cumberland County Sheriff Casey Cox failed to investigate information Webb provided concerning events occurring primarily in 2021 and 2022. The court granted leave to proceed in forma pauperis and conducted mandatory screening. It concluded that the claims were barred by Tennessee's one-year limitations period for § 1983 actions and alternatively failed to state a claim against Cox in either his individual or official capacity.