Jones v. Richardson, 6:22-cv-02162-BHH

Plaintiff Edward Gordon Jones filed a civil complaint alleging various federal constitutional violations against defendants Doug Richardson, Stuart Surratt, Brandon Prino, and Catherine Dursse.
Magistrate Judge Molly H. Cherry ordered Plaintiff to provide paperwork and noted pleading deficiencies; Plaintiff filed an amended complaint and several letters in response.
The Magistrate Judge issued a Report recommending summary dismissal for multiple reasons: release is not available under 42 U.S.C. § 1983; Younger abstention; failure to plausibly plead Fourth Amendment claims against Prino and Richardson; failure to show Surratt and Dursse acted under color of state law; failure to plead violations of the Seventh, Ninth, Tenth, or Thirteenth Amendments; and declining supplemental jurisdiction over state-law claims.
The Report notified the parties of their right to object; no objections were filed within the time allowed.
The district court reviewed the record for clear error, agreed with the Magistrate Judge’s analysis, adopted the Report, and dismissed the action without prejudice, without leave to amend, and without issuance and service of process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Availability of release under §1983	Jones sought release from prison as relief	Release is not an available remedy under §1983	Release is not available under §1983; claim dismissed
Interference with ongoing state criminal proceedings (Younger)	Federal relief permitted despite parallel state proceedings	Federal court should abstain under Younger to avoid interfering	Younger abstention applies; federal court will not interfere
Fourth Amendment claims against Prino and Richardson	Alleged unlawful search/seizure by Prino and Richardson	Pleading lacks plausible factual support for a Fourth Amendment claim	Claims insufficiently pleaded and dismissed
State-action requirement for Surratt and Dursse	Alleged constitutional violations by Surratt and Dursse	Failed to allege they acted under color of state law	Allegations insufficient; claims dismissed
Claims under Seventh, Ninth, Tenth, Thirteenth Amendments	Asserted violations of these Amendments	Allegations do not plausibly state cognizable federal claims	Court found no plausible violations; claims dismissed
Supplemental jurisdiction over state-law claims	Asserted state-law claims along with federal claims	No valid federal claim; court should decline supplemental jurisdiction	Court declined to exercise supplemental jurisdiction; state-law claims dismissed

Younger v. Harris, 401 U.S. 37 (1971) (federal courts should not enjoin ongoing state criminal proceedings)
Mathews v. Weber, 423 U.S. 261 (1976) (magistrate judge’s recommendation has no presumptive weight)
Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310 (4th Cir. 2005) (absent timely objection, district court reviews magistrate report for clear error)