Blackstock v. Rucker
4:17-cv-02079
| D.S.C. | Sep 1, 2017Background
- Plaintiff Sepia Vonnetta Blackstock, proceeding pro se and in forma pauperis, sued mental-health provider Sylvia L. Rucker for alleged false statements on Social Security forms submitted in connection with Plaintiff’s 2008 disability application.
- Plaintiff alleges First Amendment harm and seeks $76,000 for pain, suffering, emotional distress, and reputational injury.
- Complaint was reviewed under 28 U.S.C. § 1915 screening standards and pro se liberal-construction precedents.
- The magistrate judge found no factual allegations that Rucker acted under color of state law when preparing the Social Security forms.
- The magistrate concluded there is no federal constitutional cause of action for defamation and, alternatively, any state-law defamation claim is barred by South Carolina’s two-year statute of limitations based on the 2008 date.
- Recommendation: dismiss the Complaint without prejudice, and notify Plaintiff of right to object to the Report and Recommendation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Defendant acted under color of state law for § 1983 liability | Rucker’s allegedly false Social Security form entries deprived Blackstock of First Amendment-protected interests | Rucker was a private medical provider; not a state actor when preparing the forms | Dismissed: no allegations show state action; § 1983 claim fails |
| Whether reputational injury states a federal constitutional claim | False statements on forms violated Plaintiff’s constitutional rights | Reputation-only injuries are not constitutional violations | Dismissed: no federal right to be free from defamation under § 1983 |
| Whether a state-law defamation claim is viable despite delay | Plaintiff alleges defamation from 2008 report and seeks damages | Defendant asserts statute of limitations expired | Dismissed: South Carolina two-year statute bars suit based on 2008 publication |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (1989) (sua sponte dismissal under in forma pauperis screening)
- Estelle v. Gamble, 429 U.S. 97 (1976) (liberal construction of pro se pleadings)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints held to less stringent standard)
- Paul v. Davis, 424 U.S. 693 (1976) (reputation alone does not invoke due process protection)
- Monroe v. Page, 365 U.S. 167 (1961) (§ 1983 requires action under color of state law)
- United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (dismissal principles; pendent jurisdiction guidance)