Hamilton, Jr. v. Riggins, 2:20-cv-04103

Pro se plaintiff Kevin L. Hamilton, Jr. filed suit against Melissa K. Riggins and sought leave to proceed in forma pauperis; IFP status was granted.
The Court conducted an initial screening under 28 U.S.C. § 1915(e)(2)(B) to identify frivolous or noncognizable claims.
Hamilton’s entire statement of claim alleges: personal injury, breach of contract, attorney–client relationship, and discrimination, and requests various monetary amounts and a court date.
The Complaint contains no factual allegations or context supporting those labels—only conclusory assertions.
Applying Rule 8(a) and the Twombly/Iqbal pleading standards (with usual pro se leniency), the magistrate judge found the pleading insufficiently factual.
Recommendation: dismiss the Complaint under § 1915(e)(2)(B)(ii) for failure to state a claim; parties have 14 days to file objections (failure to object waives de novo review/appeal).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Complaint should be dismissed under § 1915(e)(2)(B) for failure to state a claim	Hamilton alleges personal injury, breach of contract, attorney–client relationship, discrimination, and seeks damages/court date	No substantive defense presented at screening	Recommended dismissal under § 1915(e)(2)(B)(ii) for failure to state a claim
Whether pro se status alters pleading requirements	Pro se complaints should be judged leniently	N/A	Court applies relaxed view but requires factual allegations; leniency has limits
Whether conclusory allegations meet Twombly/Iqbal plausibility standard	Plaintiff’s labels and conclusions suffice to assert claims	N/A	Conclusory "naked assertions" insufficient; must plead factual content to permit plausible inference of liability
Procedure for review of the R&R and consequences of no objection	N/A	N/A	Parties have 14 days to object; failure to object waives de novo review and appeal rights

Denton v. Hernandez, 504 U.S. 25 (1992) (IFP statute lowers access barriers but permits dismissal of frivolous suits)
Neitzke v. Williams, 490 U.S. 319 (1989) (IFP litigants may file without economic deterrent; supports dismissal of frivolous claims)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual matter to state a plausible claim; conclusory allegations insufficient)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (establishes the plausibility standard for pleadings)
Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (applies Rule 12(b)(6) standards to § 1915 screening)
16630 Southfield Ltd. P’ship v. Flagstar Bank, 727 F.3d 502 (6th Cir. 2013) (Rule 8 requires factual and legal allegations beyond labels)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are construed liberally)
Frengler v. Gen. Motors, [citation="482 F. App'x 975"] (6th Cir. 2012) (courts are not required to guess at the nature of pro se claims)
Wells v. Brown, 891 F.2d 591 (6th Cir. 1989) (courts should not have to guess at the claims asserted)
Pfahler v. Nat’l Latex Prod. Co., 517 F.3d 816 (6th Cir. 2007) (failure to object to a magistrate judge’s R&R waives appeal)
United States v. Sullivan, 431 F.3d 976 (6th Cir. 2005) (failure to timely object to an R&R can waive appellate review)
Robert v. Tesson, 507 F.3d 981 (6th Cir. 2007) (general objections that fail to specify issues do not preserve them for appeal)