Coyle v. Jackson, 702 F. App'x 727

Pro se plaintiff William A. Coyle sued after being discharged from a Colorado treatment center, alleging discrimination (color, religion, disability) under Title VI and citing various criminal statutes; initial complaint used unnamed defendants.
Magistrate judge found the complaint deficient for failing to identify defendants and for lacking the short, plain statement of facts required by Federal Rule of Civil Procedure 8; ordered an amended complaint.
Coyle filed an amended complaint naming Cynthia A. Jackson and a Brian “Doe”; magistrate again found allegations unchanged and granted one more chance to comply with Rule 8.
Coyle’s second amended complaint remained vague, conclusory, and failed to connect facts to legal rights; the district court dismissed the complaint without prejudice for failing to comply with Rule 8 and certified the appeal would not be taken in good faith.
Coyle appealed and sought in forma pauperis (IFP) status on appeal; the Tenth Circuit affirmed dismissal and denied IFP status, concluding the appeal was not taken in good faith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal under Rule 41(b)/Rule 8 was proper for failure to plead a short, plain statement	Coyle argued his pro se filings should be liberally construed and dismissal was improper	Court argued pleadings were disjointed, vague, and failed to give fair notice despite multiple chances	Affirmed: dismissal without prejudice was within district court’s discretion for Rule 8 deficiencies
Whether magistrate judge required party consent under 28 U.S.C. § 636	Coyle argued magistrate involvement required his consent	Court asserted magistrate was properly handling pretrial matters under § 636(b)(1)(A) without consent	Held: magistrate’s role was proper and did not require Coyle’s consent
Whether defendants were required to answer before dismissal (Rule 12)	Coyle argued defendants should have been required to answer within 21 days	Court maintained it may dismiss sua sponte for pleading deficiencies without awaiting answers	Held: dismissal without awaiting answers was permissible and not an advocacy for defendants
Whether appeal is taken in good faith for IFP status	Coyle sought IFP on appeal, asserting errors below	Court found Coyle failed to present a reasoned, nonfrivolous argument addressing pleading defects	Held: appeal not in good faith; IFP status on appeal denied

Nasious v. Two Unknown B.I.C.E. Agents, 492 F.3d 1158 (10th Cir. 2007) (standard and deference for Rule 41(b)/Rule 8 dismissals)
Rocky Mountain Christian Church v. Bd. of Cty. Comm’rs, 613 F.3d 1229 (10th Cir. 2010) (abuse-of-discretion standard for dismissals)
Mann v. Boatright, 477 F.3d 1140 (10th Cir. 2007) (court not required to construct claims from deficient pro se pleadings)
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (district courts may manage docket and dismiss sua sponte)
DeBardeleben v. Quinlan, 937 F.2d 502 (10th Cir. 1991) (good-faith standard for IFP appeals)
Olsen v. Mapes, 333 F.3d 1199 (10th Cir. 2003) (Rule 41(b) may be applied sua sponte)
Erickson v. Pardus, 551 U.S. 89 (2007) (liberal construction of pro se pleadings, with limits)
United States v. Pinson, 584 F.3d 972 (10th Cir. 2009) (liberal construction does not allow courts to act as advocate)