Elijah Ratcliff v. State of Texas, 699 F. App'x 410

Pro se plaintiff Elijah W. Ratcliff filed an amended complaint asserting multiple, poorly-pleaded civil-rights claims against Texas, municipal and county entities, private parties, and various officials; many claims mirrored an earlier suit by Ratcliff.
The magistrate judge reviewed pending motions, recommended dismissal for failure to state a claim, and found at least one defendant entitled to sovereign immunity.
The magistrate recommended monetary sanctions against Ratcliff: $1,500 to the court clerk and $4,200 to the City of Livingston for fees and expenses.
The district court adopted the magistrate judge’s report, dismissed all claims, and imposed the recommended sanctions; Ratcliff objected but raised no specific rebuttal of the recommendations.
On appeal, Ratcliff failed to identify errors in the dismissal or address the sanctions; he also challenged the denial of his motion to disqualify the district judge based on alleged bias.
The Fifth Circuit reviewed the recusal denial for abuse of discretion and found Ratcliff’s affidavit too vague to show actual or apparent bias; it affirmed the dismissal and sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amended complaint states a claim	Ratcliff asserted various civil-rights violations (rambling, conclusory allegations)	Defendants moved to dismiss for failure to state a claim and sovereign immunity where applicable	Court dismissed the complaint for failure to state a claim; some defendants shielded by sovereign immunity
Whether sanctions were appropriate	Ratcliff did not meaningfully contest sanctions on appeal	City of Livingston sought fees and costs under applicable standards	Sanctions affirmed (court adopted magistrate’s recommendation: $1,500 to clerk; $4,200 to City)
Whether the judge should have been disqualified (28 U.S.C. §§ 144, 455)	Ratcliff alleged actual and apparent bias based on vague assertions (e.g., request to initiate unauthorized-practice charge; affinity contrary to certain administrative decisions)	Defendants argued affidavit lacked particularized facts showing bias; recusal standards not met	Recusal denied; affidavit was too vague to show actual or apparent bias; denial affirmed
Whether pro se status excuses briefing requirements	Ratcliff relied on pro se status and filed a rambling brief	Defendants and court pointed to Rule 28 and precedent requiring meaningful briefing despite pro se status	Court held pro se litigants are liberally construed but must still brief issues; claims not raised on appeal were abandoned

Grant v. Cuellar, 59 F.3d 523 (5th Cir. 1995) (pro se briefs construed liberally but must comply with appellate briefing rules)
Brinkmann v. Dallas Cty. Deputy Sheriff Abner, 813 F.2d 744 (5th Cir. 1987) (claims not raised on appeal are deemed abandoned)
Chitimacha Tribe of La. v. Harry L. Laws Co., Inc., 690 F.2d 1157 (5th Cir. 1982) (standard of review and test for judicial disqualification under § 455)
Henderson v. Dep’t of Pub. Safety & Corr., 901 F.2d 1288 (5th Cir. 1990) (requirements for a § 144 affidavit to show actual bias)