Carter v. Chase, 4:17-cv-02201

Plaintiff Keithlan Carter, detained at Southeast Behavioral Health Center, sued multiple Salem and Dent County law-enforcement officers, the Walnut Bowl Inn owner and clerk, and the State of Missouri under 42 U.S.C. § 1983 alleging false arrest, a conspiracy to kill or arrest him, and threats arising from prior testimony.
Core allegation: in late 2013 Officer Joe Chase forced Carter to touch a handgun to later frame him; Carter claims a drug gang put a bounty on him after his testimony in a prior federal case and that officers and hotel staff conspired with a hit-man to kill or falsely arrest him on Sept. 12, 2014.
Public records show Carter was arrested on September 12, 2014 and charged in multiple state criminal cases; he remains subject to probation and is detained under probation-related terms.
Carter sought $20 million and placement in a witness protection program; he also filed a financial affidavit and requested appointed counsel and in forma pauperis status.
The court granted in forma pauperis status (no filing fee assessed at that time) but—relying on Wallace v. Kato—stayed and administratively closed the § 1983 action pending final resolution of Carter’s underlying criminal matters (including probation, appeals, and post-conviction remedies).
The court denied Carter’s motion for counsel without prejudice and ordered him to notify the court within 30 days after final disposition of the criminal matters if he seeks to reopen the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff may proceed without prepayment of the filing fee	Carter asserted inability to pay and submitted a financial affidavit	No opposition; court reviewed affidavit and account statements (none produced)	Granted IFP; no fee assessed at this time
Whether the complaint must be screened/dismissed under 28 U.S.C. § 1915(e)(2)(B) (frivolous/PLS)	Carter alleges false arrest, conspiracy, and threats sufficient to state claims	Court considered legal standards for frivolity and failure to state a claim	Court did not dismiss on screening but concluded a stay was appropriate under Wallace instead of immediate merits review
Whether the federal § 1983 claims should proceed while related state criminal proceedings and probation are unresolved	Carter filed civil false-arrest/conspiracy claim while on probation for the underlying arrests	Defendants did not advance a separate argument in the opinion; court evaluated prudential concerns and Wallace guidance	Stayed and administratively closed the civil action until final disposition of criminal charges, probation, appeals, and post-conviction remedies
Whether counsel should be appointed	Carter requested appointed counsel	No live argument found; court applied discretionary factors	Denied without prejudice (may be revisited if case reopened)

Wallace v. Kato, 549 U.S. 384 (stay of civil false-arrest claims pending resolution of related criminal proceedings)
Neitzke v. Williams, 490 U.S. 319 (frivolousness standard for § 1915 dismissals)
Denton v. Hernandez, 504 U.S. 25 (standards for dismissing frivolous in forma pauperis claims)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)