Jaime Mendez Cuellar v. Eric Guerrero, et al.

Summary

The United States District Court for the Southern District of Texas dismissed Jaime Mendez Cuellar’s pro se 42 U.S.C. § 1983 action against Texas prison officials. The court held that his sovereign-citizen and mistaken-identity allegations were frivolous and that his claims concerning the handling of prison grievances failed to state a constitutional or federal-law violation; the dismissal was with prejudice and counted as a strike under 28 U.S.C. § 1915(g).

Holdings

1. Claims premised on sovereign-citizen theories that a prisoner is not subject to state or federal law, or that imprisonment is unlawful because his name was written in uppercase letters, are frivolous and fail to state a claim under § 1983.
2. A prisoner has no federally protected liberty interest or due-process right in the adequacy, investigation, handling, or favorable resolution of prison administrative grievances.
3. A prisoner's in forma pauperis complaint must be dismissed when it is frivolous or fails to state a claim upon which relief may be granted; Cuellar's complaint satisfied both grounds for dismissal.

Questions Presented

1. Whether Cuellar's sovereign-citizen and mistaken-identity allegations stated a viable claim under 42 U.S.C. § 1983.
2. Whether prison officials' alleged failure to process or adequately resolve Cuellar's grievances violated a federally protected right.
3. Whether the complaint was subject to dismissal with prejudice as frivolous or for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B).

Disposition

dismissed