HENDERSON v. MAINE STATE PRISON
HENDERSON v. MAINE STATE PRISON
Trial Court Opinion
UNITED STATES DISTRICT COURT DISTRICT OF MAINE KURTIS HENDERSON, ) ) Plaintiff, ) ) v. ) 1:25-cv-00412-SDN ) MAINE STATE PRISON, et al., ) ) Defendants ) RECOMMENDED DECISION AFTER REVIEW OF PLAINTIFF’S COMPLAINT Plaintiff, who is in custody at the Maine State Prison, filed a complaint against the prison and two correctional officers. (Complaint, ECF No. 1.) In addition to his complaint, Plaintiff filed an application to proceed without prepayment of fees (ECF No. 4), which application the Court granted. (Order, ECF No. 5.) In accordance with the statute that governs actions where a plaintiff proceeds without prepayment of fees, a preliminary review of Plaintiff’s complaint is appropriate.
28 U.S.C. § 1915(e)(2). Additionally, Plaintiff’s complaint is subject to screening “before docketing, if feasible or … as soon as practicable after docketing,” because he is “a prisoner seek[ing] redress from a governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). After a review of Plaintiff’s complaint, I recommend the Court dismiss the complaint unless Plaintiff files an amended complaint alleging an actionable claim. DISCUSSION
28 U.S.C. § 1915is designed to ensure meaningful access to the federal courts for individuals unable to pay the cost of bringing an action. When a party is proceeding
pursuant to § 1915, however, “the court shall dismiss the case at any time if the court determines,” inter alia, that the action is “frivolous or malicious” or “fails to state a claim on which relief may be granted.”
28 U.S.C. § 1915(e)(2)(B). “Dismissals [under § 1915] are often made sua sponte prior to the issuance of process, so as to spare prospective defendants the inconvenience and expense of answering such complaints.” Neitzke v.
Williams,
490 U.S. 319, 324(1989). The § 1915A screening requires courts to “identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint (1) is frivolous, malicious, or fails to state a claim …; or (2) seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b). When considering whether a complaint states a claim for which relief may be
granted, courts must assume the truth of all well-plead facts and give the plaintiff the benefit of all reasonable inferences therefrom. Ocasio-Hernandez v. Fortuno-Burset,
640 F.3d 1, 12(1st Cir. 2011). A complaint fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly,
550 U.S. 544, 570(2007). “A self-represented
plaintiff is not exempt from this framework, but the court must construe his complaint ‘liberally’ and hold it ‘to less stringent standards than formal pleadings drafted by lawyers.’” Waterman v. White Interior Sols., No. 2:19-cv-00032-JDL,
2019 WL 5764661, 2 at *2 (D. Me. Nov. 5, 2019) (quoting Erickson v. Pardus,
551 U.S. 89, 94(2007)). “This is not to say that pro se plaintiffs are not required to plead basic facts sufficient to state a
claim.” Ferranti v. Moran,
618 F.2d 888, 890(1st Cir. 1980). Here, Plaintiff alleges that he filed grievances, which were denied, but Plaintiff does not describe the substance of the grievances or otherwise explain the factual basis for any claims against the named defendants. In his complaint, Plaintiff simply asserts that he is seeking compensatory and punitive damages. In an attachment to the complaint, Plaintiff refers to an “assault,” but provides no other information from which the Court could
determine whether Plaintiff has alleged an actionable claim. (Initial Disclosure, ECF No. 1-1.) Given the lack of specific facts, Plaintiff has not alleged “a claim to relief that is plausible on its face.” Twombly,
550 U.S. at 570. Dismissal, therefore, is warranted. CONCLUSION Based on the foregoing analysis, after a review of Plaintiff’s complaint pursuant to
28 U.S.C. §§ 1915and 1915A, I recommend the Court dismiss the matter unless, within fourteen days of the date of this recommended decision, Plaintiff files an amended complaint with sufficient facts to support an actionable claim. NOTICE A party may file objections to those specified portions of a magistrate judge’s report or proposed findings or recommended decisions entered pursuant to
28 U.S.C. § 636(b)(1)(B) for which de novo review by the district
3 court is sought, together with a supporting memorandum, within fourteen (14) days of being served with a copy thereof.
Failure to file a timely objection shall constitute a waiver of the right to de novo review by the district court and to appeal the district court’s order.
/s/ John C. Nivison U.S. Magistrate Judge Dated this 26th day of August, 2025.
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Reference
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