Karl Williams, III v. Caleb Cathey, et al.

Summary

The United States District Court for the Middle District of Tennessee grants Karl Williams, III’s amended application to proceed in forma pauperis and conducts an initial screening of his amended civil-rights complaint arising from a traffic stop, arrest, search, and alleged use of excessive force. The court permits the individual-capacity federal claims against three deputies and the related state-law claims to proceed, but dismisses the sheriff and all official-capacity claims for failure to plausibly plead municipal liability. The court also denies without prejudice the plaintiff’s motion for leave to file a third amended complaint because no proposed pleading was attached.

Holdings

1. Plaintiff's amended application sufficiently demonstrated that he could not pay the civil filing fee in advance without undue hardship, so the amended IFP application was granted and the original application was denied as moot.
2. The federal claims against Defendants Cathey, Early, and Richardson in their individual capacities, and the pendent state-law claims, were sufficiently pleaded to proceed beyond initial review.
3. The official-capacity claims against Cathey, Early, and Richardson and the claim against Sheriff Cox were dismissed because the complaint did not plausibly allege that a specific Cumberland County policy or custom was the moving force behind a constitutional deprivation.
4. The motion for leave to file a third amended complaint was denied without prejudice because Plaintiff did not attach the proposed amended complaint as required by Local Rule 15.01(a)(1).

Questions Presented

1. Whether Plaintiff qualified to proceed in forma pauperis under 28 U.S.C. § 1915(a).
2. Whether the amended complaint stated plausible federal and pendent state-law claims against the deputies in their individual capacities at the initial-screening stage.
3. Whether the amended complaint plausibly alleged municipal liability against the sheriff in his official capacity and against the deputies in their official capacities.
4. Whether Plaintiff's motion for leave to file a third amended complaint complied with the local rule requiring an attached proposed amended pleading.

Disposition

other