Hall v. Zeitler
3:19-cv-30134
D. Mass.Sep 21, 2020Background
- Plaintiff Adam L. Hall, a pro se prisoner serving life for three murders, alleges Hells Angels and individual members promised criminal defense counsel and protection of his property but cut him off in 2011 after police questioning.
- Hall claims the defendants failed to provide counsel and that Hells Angels members stole his real and personal property; he previously filed a similar RICO suit in 2015 that was dismissed.
- Hall filed the instant action in 2019 and submitted a sealed Second Amended Complaint after court orders; he proceeds in forma pauperis.
- The magistrate judge screened the SAC under 28 U.S.C. § 1915(e)(2) and § 1915A and found it violates Rule 8 (overly long, unnumbered narrative) and gave multiple amendment opportunities.
- The court concluded Hall’s RICO claims are time-barred (four-year limitations with accrual when injury is or should be known) and, alternatively, fail on the merits per the court’s prior RICO analysis.
- Because no viable federal claim remains, the court found diversity jurisdiction absent and recommended declining supplemental jurisdiction over any state-law claims and dismissing the action with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 8 sufficiency of pleading | Hall contends his narrative alleges the promises and breaches by Hells Angels | Defendants argue complaint is noncompliant, not a short/plain statement and impossible to answer | Court: SAC violates Rule 8; dismissal appropriate (court nonetheless reached merits) |
| In forma pauperis screening standard | Hall seeks to proceed IFP and avoid dismissal | Court applies §1915(e)(2) screening for frivolous/failed claims | Court: SAC subject to screening; dismissal warranted under §1915(e)(2) |
| RICO statute of limitations (accrual) | Hall alleges injuries from 2011 onward; filed 2019 | Defendants argue four-year RICO limitations began by 2011 (or by 2014/2015) so claims are untimely | Court: RICO claims time-barred; prior 2015 suit did not toll the limitations |
| Adequacy of RICO pleading on merits | Hall alleges pattern of racketeering and enterprise conduct | Defendants maintain allegations do not satisfy RICO elements and prior RICO dismissal controls | Court: Even if timely, SAC fails to state a RICO claim; recommends dismissal with prejudice |
| Subject-matter jurisdiction over state claims | Hall invoked diversity jurisdiction | Defendants observe parties are not completely diverse; Hall presumed MA domiciliary despite Florida incarceration | Court: No complete diversity; declines supplemental jurisdiction over state claims |
Key Cases Cited
- Denton v. Hernandez, 504 U.S. 25 (IFP suits may be dismissed if frivolous or fail to state a claim)
- Haines v. Kerner, 404 U.S. 519 (pro se pleadings liberally construed)
- Rotella v. Wood, 528 U.S. 549 (RICO limitations accrual when plaintiff knew or should have known of injury)
- Padmanabhan v. Hulka, 308 F. Supp. 3d 484 (local application: RICO four-year limitation and pleading standards)
- López-González v. Municipality of Comerío, 404 F.3d 548 (dismissal without prejudice as sanction does not toll federal statute of limitations)
- Hall v. Curran, 599 F.3d 70 (prisoner domicile presumed at pre-incarceration domiciliary state for diversity purposes)
- Rodríguez v. Doral Mortg. Corp., 57 F.3d 1168 (district court may decline supplemental jurisdiction after dismissal of federal claims)
- Zell v. Ricci, 957 F.3d 1 (reinforcing that district courts generally should not retain pendent state claims when federal anchors are dismissed)