Griffin v. City of Milwaukee, 2:23-cv-00328

Pro se plaintiff Ieshuh Griffin filed a 52-page complaint (plus exhibits) alleging widespread election fraud and that she was wrongly denied ballot placement for a Milwaukee municipal judgeship.
Complaint named ~15+ defendants (City of Milwaukee, Milwaukee Election Commission, State of Wisconsin, Governor, mayor, election officials, judges, others) but largely failed to attribute specific acts to individual defendants.
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6) and for failure to comply with Rule 8 and insufficient service; Court found pleading incoherent, conclusory, and legally deficient.
Court determined municipal charter’s attorney-licensure requirement for Milwaukee municipal judges is valid and Griffin does not meet it.
Court noted Griffin’s long history of similar, dismissed suits in federal and state courts and that many claims had been previously adjudicated or dismissed.
Court dismissed the action with prejudice, imposed a five-year filing bar in the Eastern District, and ordered Griffin to pay reasonable attorneys’ fees incurred by appearing defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Pleading sufficiency / Rule 8	Griffin alleged election fraud and numerous federal/state claims in a lengthy filing	Complaint is rambling, conclusory, and fails to provide fair notice as required by Rule 8	Court: Complaint fails Rule 8 and 12(b)(6) standards; dismissal warranted
Ability to seek monetary relief from state defendants (Eleventh Amendment)	Griffin sought money damages from state entities/officials	States are immune from suit for monetary relief absent consent	Court: Eleventh Amendment bars monetary claims against the State defendants
Validity of municipal-judge eligibility requirement	Griffin contends attorney-licensure requirement is fictitious/unlawful and prevented her ballot access	City points to City Charter authority and state practice allowing municipalities to impose such a requirement	Court: City may lawfully require municipal judges be licensed Wisconsin attorneys; Griffin not eligible for ballot placement
Res judicata / repeated filings and sanctions	Griffin refiled similar election claims after prior dismissals in other federal courts	Defendants note prior adjudications, pattern of frivolous filings, and misuse of process	Court: Prior dismissals operate as decisions on the merits; barred relitigation; imposed 5-year filing injunction and fee sanction

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not assumed true on a motion to dismiss)
Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) (pro se pleadings still must give fair notice; courts need not accept implausible allegations)
Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous suits lack arguable basis in law or fact)
Denton v. Hernandez, 504 U.S. 25 (1992) (definition of legally frivolous claims)
Kimel v. Florida Bd. of Regents, 528 U.S. 62 (2000) (Eleventh Amendment immunity principles)
Coniston Corp. v. Vill. of Hoffman Ests., 844 F.2d 461 (7th Cir. 1988) (mistaken application of state law does not give rise to substantive due process claim)
Lee v. Village of River Forest, 936 F.2d 976 (7th Cir. 1991) (12(b)(6) dismissal has res judicata effect)
In re Chapman, 328 F.3d 903 (7th Cir. 2003) (narrowly tailored filing restrictions may be imposed to curb abusive litigation)