Guntle v. Cass County Sheriff's Office, 1:24-cv-00881

Plaintiff Travis Guntle, while detained in Cass County Jail for a probation violation, brought this pro se action against the Cass County Sheriff’s Office, Tribal Police, and Dowagiac Police Department.
Guntle claimed his rights were violated when these entities allegedly aided and abetted a false domestic violence accusation that led to his confinement.
The domestic violence accusation was the basis for the probation violation; Guntle eventually pleaded guilty and was sentenced to 365 days, with credit for time served.
He asserted federal claims under 42 U.S.C. § 1983, alleging Fourteenth Amendment violations, and supplemental state law claims (defamation, infliction of mental distress).
The court screened the complaint under the Prison Litigation Reform Act and other relevant statutes, focusing on whether the complaint stated a claim upon which relief could be granted.
The court found the complaint lacking in factual specificity and legal sufficiency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourteenth Amendment Due Process violation	Detained based on a false accusation, thus denied due process	No constitutional violation since all normal procedures were followed	No procedural due process violation; plaintiff received all due process required
Fourth Amendment Malicious Prosecution	Prosecution was based on a fabricated charge	No favorable termination for plaintiff; probable cause existed due to guilty plea	No malicious prosecution claim; case did not terminate in plaintiff’s favor
State-law torts (defamation, mental distress)	Defendants committed state torts as part of wrongful charge	Federal courts lack jurisdiction if federal claims are dismissed	State law claims dismissed without prejudice; court declines supplemental jurisdiction
Appeal in good faith	Claims present non-frivolous appellate issues	Claims are baseless and unsupported	Appeal would not be taken in good faith

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets pleading standards for stating a claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints require more than conclusory statements)
West v. Atkins, 487 U.S. 42 (1988) (§ 1983 requires violation by state actor)
Albright v. Oliver, 510 U.S. 266 (1994) (§ 1983 first step is to identify specific constitutional right)
Giglio v. United States, 405 U.S. 150 (1972) (prosecutorial misconduct for knowing use of perjured testimony)
Mooney v. Holohan, 294 U.S. 103 (1935) (deliberate deception involving false evidence is a constitutional violation)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966) (supplemental jurisdiction over state law claims)