Isadoris Green v. Nicholas Alexander

Summary

The United States District Court for the Western District of Wisconsin screened Isadoris Green’s pro se complaint alleging that a Douglas County sheriff struck him with a squad car because of his race and false charges. The court dismissed the complaint for failure to state a claim, identified insufficient factual allegations and potential statute-of-limitations concerns, and granted Green until January 17, 2026, to file an amended complaint.

Holdings

1. The complaint failed to state a plausible Fourth Amendment excessive-force claim because its allegations were too sparse and inconsistent to identify who did what, and it did not identify any action by Alexander, the sole named defendant.
2. Dismissal was warranted under 28 U.S.C. §§ 1915(e)(2) and 1915A because the complaint failed to state a claim upon which relief could be granted.
3. The court noted that claims based on the 2016 events appeared untimely, but permitted Green to amend and required him to explain why he waited more than nine years to file suit.

Questions Presented

1. Whether Green's complaint stated a plausible Fourth Amendment excessive-force claim against the sole named defendant.
2. Whether the complaint was subject to dismissal at screening because it failed to identify the actors and conduct underlying the alleged constitutional violation.
3. Whether the apparent expiration of the statute of limitations warranted dismissal or required Green to address the delay in an amended complaint.

Disposition

dismissed