Artis Anderson v. Vanessa Dickson, 16-6290

Background

Artis Anderson (pro se) sued a range of defendants (state judges, CHFS employees, police, paramedics, medical providers, and an assisted‑living facility) arising from events after his elderly wife Mary Ellen Reynolds — alleged to have dementia — was taken to a hospital and later placed under a guardian; CHFS later sought annulment of the marriage.
Anderson alleged violations of 42 U.S.C. §§ 1981, 1983, and 1985 (due process, interference with marriage and contracts, conspiracy, and related state-law claims) and sought a preliminary injunction and damages; he amended the complaint to add more defendants.
The district court denied injunctive relief, dismissed all federal claims with prejudice, dismissed state-law claims without prejudice, and denied IFP on appeal as frivolous; Anderson paid the appellate fee and appealed.
The Sixth Circuit reviewed de novo Rule 12(b)(6) dismissals and abuse-of-discretion for the injunction and supplemental-jurisdiction decisions, applying Iqbal/Twombly pleading standards and liberal construction for pro se pleadings.
The court affirmed: (1) §§ 1981 and 1985 claims dismissed for lack of class‑based or conspiracy allegations; (2) official-capacity claims dismissed for lack of Monell allegations; (3) judges entitled to absolute judicial immunity; (4) conspiracy and § 1983 claims inadequately pleaded; (5) state-law claims dismissed without prejudice; (6) preliminary injunction denial affirmed.
The court found the appeal frivolous as filed out of "sheer obstinacy," granted motions for sanctions in part, remanded to determine amount and ability to pay, and directed the district court to place Anderson on a filer‑approval requirement.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of § 1981 and § 1985 claims	Anderson claimed racial/class or conspiratorial interference with rights	Defendants argued no racial/class‑based or properly pleaded conspiracy conduct	Dismissed: no allegations of class‑based discrimination or required conspiracy elements
Official‑capacity (Monell) liability	Anderson sought to hold officials and agencies liable in their official roles	Defendants: no municipal policy/custom alleged to ground Monell liability	Dismissed: Anderson failed to allege policy or custom sufficient for Monell
Claims against state judges (judicial immunity)	Judges acted without jurisdiction and thus immune shield should not apply	Judges: actions were judicial acts within jurisdiction	Dismissed: judges entitled to absolute judicial immunity; Anderson’s jurisdictional claims were merits challenges, not clear absence of jurisdiction
Conspiracy / private parties under § 1983	Anderson alleged private actors conspired with state actors to deprive rights	Defendants: no state‑action allegations or specific overt acts alleged	Dismissed: conclusory allegations insufficient to plead conspiracy or state action
Standing / substantive constitutional claims re: emergency transport and welfare checks	Anderson asserted harm from paramedics transporting Reynolds and officer recording / trespass threats	Defendants: actions did not injure Anderson’s constitutional rights and he lacked standing; recordings not private; marriage annulled so marital‑association claims fail	Dismissed: no injury‑in‑fact; no reasonable expectation of privacy; annulment means no protected marital interest
Preliminary injunction	Anderson argued irreparable harm and likelihood of success	Defendants: no likelihood of success, injunction would harm Reynolds and public interest	Denied: Anderson failed to show likelihood of success or irreparable harm; injunction could harm incompetent Reynolds; public interest disfavors injunction
Sanctions and future filing restrictions	Anderson continued repeated meritless filings and appeals	Defendants sought fees/costs under Rule 38 and statutory authority	Sanctions conditionally granted: appeal deemed frivolous for obstinacy; remanded to determine amount; district court ordered to require leave before new filings

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: factual plausibility required)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility and conspiracy pleading standard)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires policy or custom)
Mireles v. Waco, 502 U.S. 9 (1991) (absolute judicial immunity for judicial acts)
Stump v. Sparkman, 435 U.S. 349 (1978) (scope of judicial immunity)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Rooker‑Feldman bar on federal review of state court judgments)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing: injury‑in‑fact requirement)
Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985) (procedural due process principles regarding liberty/property interests)