William D. Allen v. Mandy Bondy, et al.

Summary

The United States District Court for the Northern District of Indiana screened William D. Allen’s prisoner complaint under 28 U.S.C. § 1915A. The court concluded that the complaint did not state viable due process, equal protection, Fourth Amendment, or state-law abuse-of-process claims and appeared untimely. The court granted Allen until June 4, 2026, to file an amended complaint and cautioned that failure to do so would result in dismissal.

Holdings

1. The complaint did not state a procedural due-process or equal-protection claim because Allen alleged that he repeatedly sought relief in the Indiana courts and did not show that he lacked constitutionally adequate procedural safeguards.
2. The complaint did not state a Fourth Amendment claim based on the alleged inaccurate information used to obtain the warrant because Allen did not dispute that probable cause existed for the charged crimes.
3. The allegations did not state an Indiana abuse-of-process claim because they did not plausibly show an ulterior purpose and a willful act in the use of process that was improper in the regular conduct of the proceeding.
4. Absent a valid federal claim, Allen could proceed on the state-law abuse-of-process claim only if complete diversity existed, and the allegations did not establish complete diversity because Allen, Bondy, and Widner were alleged to be Indiana citizens.
5. The claims appeared untimely because the alleged injury accrued no later than July 22, 2022, while Allen did not file the complaint until March 2, 2026, beyond the applicable two-year limitations period.
6. Allen was granted until June 4, 2026, to file an amended complaint consistent with the events described in the existing complaint.

Questions Presented

1. Whether the complaint stated a procedural due-process or equal-protection claim based on the alleged deprivation of bond payments and lack of procedural safeguards.
2. Whether the alleged use of inaccurate information to obtain a warrant stated a Fourth Amendment claim.
3. Whether the allegations stated an Indiana abuse-of-process claim and whether the federal court had subject-matter jurisdiction over that state-law claim.
4. Whether the claims were barred by the applicable two-year statute of limitations.
5. Whether Allen should be granted leave to amend the deficient complaint.

Disposition

other