Gatlin v. Curtis, 2:24-cv-03393

Plaintiff, Jerome Gatlin, sought to proceed in forma pauperis (IFP) in federal court, alleging he could not pay court fees while affording life's necessities.
Gatlin's complaint aimed to recover a car from Defendant Aaleahiyah Ladell, alleging the car was titled in his name but was withheld by Ladell.
Plaintiff also alleged that City of Phoenix police officers and the City of Phoenix failed to assist him in obtaining the car through a "civil standby," claiming this refusal was racially motivated and a policy failure.
The complaint contained four claims: due process and equal protection claims (against officers), a § 1983 policy claim (against the City), and a state-law replevin claim (against Ladell).
The court granted IFP status, then screened the complaint under § 1915(e)(2) for failure to state a claim, examining whether the officers had any duty under Arizona law to assist in the car recovery without a court order.
The court dismissed the federal claims with prejudice, found no constitutional violation, and declined supplemental jurisdiction over the state-law replevin claim pending any amended complaint meeting statutory requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Police Duty to Assist (Civil Standby)	Officers were required to assist in car recovery as property was titled in his name.	No duty without court order; it's a civil matter.	No police duty absent court order; claim dismissed.
Due Process Violation	Refusal to assist deprived plaintiff of due process.	No constitutional right implicated.	No due process violation; claim dismissed.
Equal Protection Violation	Refusal to assist was racially motivated discrimination.	No actionable equal protection issue.	No equal protection violation; claim dismissed.
City Policy/Failure to Train	City’s deficient policies/training led to officers’ conduct.	No underlying constitutional violation.	No Monell liability; claim dismissed.

Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331 (defining standards for granting IFP status)
Lopez v. Smith, 203 F.3d 1122 (in forma pauperis screening procedures and standards)
Town of Castle Rock, Colo. v. Gonzales, 545 U.S. 748 (no general constitutional right to police enforcement)
Linda R.S. v. Richard D., 410 U.S. 614 (private citizens lack a cognizable interest in enforcing criminal laws against others)
Parratt v. Taylor, 451 U.S. 527 (reluctance to treat due process as a general tort law)
Monell v. Dept. of Soc. Servs., 436 U.S. 658 (municipal liability under § 1983)