Benson v. The Healthcare Staff of the Shelby County Criminal Justice Center
2:23-cv-02510
| W.D. Tenn. | Jun 27, 2025Background
- Plaintiff Rickey Benson, an inmate and designated "three-strikes" filer under the Prison Litigation Reform Act (PLRA), filed a complaint against the Healthcare Staff of Shelby County Criminal Justice Center, which was dismissed for procedural grounds, including failure to pay filing fees.
- The district court previously declared Benson a vexatious litigant for repeatedly filing baseless or abusive motions.
- Benson attempted several unsuccessful appeals to the Sixth Circuit, all dismissed for failure to pay proper filing fees or lack of timeliness.
- Benson filed multiple post-judgment motions in the closed case, seeking to reopen the case and obtain relief from various court orders, alleging interference with his legal mail and denial of access to the courts.
- The district court consistently denied these motions for failure to meet Rule 60(b) standards or failing to show excusable neglect or good cause for untimely filings.
- The court issued a warning that continued baseless filings would result in monetary sanctions of $100 per violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Motion for Relief under Rule 60(b) | Alleged deprivation of court order; interference with mail | No explicit argument noted; court addresses standard | Denied: No basis for relief under Rule 60(b) |
| Motion to Extend Time to Appeal | Claims postal/clerical delays and lack of notice | No explicit argument noted; court addresses standard | Denied: Untimely and no excusable neglect |
| Abuse of Judicial Process | N/A (implicit in plaintiff's continuous filings) | Court asserts repeated abuse of process by plaintiff | Warning: $100 sanction for future violations |
| Repeated Filed Motions in Closed Case | Attempts to revisit dismissal on alleged procedural error | Court invokes prior warnings and prior rulings | Motions summarily denied |
Key Cases Cited
- GenCorp, Inc. v. Olin Corp., 477 F.3d 368 (6th Cir. 2007) (explains that a Rule 60(b) motion is neither a substitute for, nor supplement to, an appeal)
- Futernick v. Sumpter Twp., 207 F.3d 305 (6th Cir. 2000) (affirms court's authority to enjoin vexatious litigants from abusing the judicial process)