Jackson v. State of Ohio
1:24-cv-02201
N.D. OhioMar 11, 2025Background
- Anthony Jackson, proceeding pro se, filed a civil complaint against the State of Ohio alleging wrongful imprisonment, false imprisonment, malicious prosecution, and violations of his Fourth, Sixth, and Eighth Amendment rights.
- The complaint invoked 42 U.S.C. § 1983 as the jurisdictional basis and sought monetary damages.
- Jackson sought to proceed in forma pauperis, which the court granted, triggering mandatory preliminary screening of his complaint under 28 U.S.C. § 1915(e)(2)(B).
- Upon screening, the court examined whether Jackson's allegations stated a plausible federal claim and whether the defendant was amenable to suit.
- The core question was whether the State of Ohio can be sued for monetary damages or injunctive relief under § 1983 or state law claims in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Ohio a proper defendant under § 1983? | Ohio liable under §1983 | Ohio is not a "person" under §1983 | States are not persons; can't be sued under §1983 |
| Does Eleventh Amendment bar suit against Ohio? | Claims are valid | State has sovereign immunity | Eleventh Amendment immunizes Ohio from suit |
| Can Ohio be sued in federal court on state-law claims? | State law violations | Consent only in state court | Only Ohio Court of Claims has jurisdiction |
| Are claims plausible under Rule 12(b)(6)/§1915? | Complaint sufficient | Insufficient factual support | Claims do not meet plausibility standard |
Key Cases Cited
- Will v. Mich. Dep't of State Police, 491 U.S. 58 (States are not "persons" for § 1983 liability)
- Ashcroft v. Iqbal, 556 U.S. 662 (Standard for plausibility in pleadings under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Plausibility requirement for complaint sufficiency)
- Guertin v. Michigan, 912 F.3d 907 (Eleventh Amendment protects states from suit by individuals)