Jurijus Kadamovas v. Michael Stevens
706 F.3d 843
| 7th Cir. | 2013Background
- Inmate plaintiff filed a Bivens suit naming seven prison staff members and several John Does alleging cruel and unusual punishment and religious-liberty infringement.
- District court dismissed the complaint as unintelligible and long, after giving leave to amend, before any defendant appeared.
- Judge concluded the 99-page complaint was incomprehensible under Rule 8 and dismissed with prejudice, prompting this appeal.
- The actual pleading was 28 pages with a 71-page appendix; the court treated it as unintelligible but recognized the pleading sought to advance multiple distinct claims.
- Plaintiff alleged retaliation through force-feeding, forced blood draws, segregation in a feces-infested cell, denial of recreational opportunities, denial of a Bible, denial of grievances, and obstruction of access to federal courts.
- On appeal, the Seventh Circuit held unintelligibility was not established and remanded for further proceedings, including potential severance or repleading as needed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissal for unintelligibility was proper | Kadamovas argues the complaint is intelligible and properly states multiple distinct claims | District court deemed it unintelligible and dismissible under Rule 8 | Unintelligibility dismissal reversed; complaint plausible under Twombly/Iqbal standards |
| Whether the complaint states a plausible claim for relief | Allegations show retaliation and denial of religious rights; sufficient plausibility | Bare or conclusory assertions insufficient without factual enhancement | Complaint exceeds mere possibilities; pleads plausible claims under governing pleading standards |
| Whether plaintiff is entitled counsel on remand | Counsel should be appointed given complexity | No prejudice shown; premature to decide pre-respondent stage | Premature to determine right to counsel; remand allows review with responsive pleadings forthcoming |
| Whether remand and potential severance/joinder were appropriate | Consolidation of all charges against all defendants is improper; sever or limit claims | Joinder constrained by Rule 20; can require separate complaints | Remanded with guidance to consider severance or separate complaints to reduce confusion |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (Supreme Court 2009) (plausibility standard for pleading a claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Supreme Court 2007) (claims require plausible entitlement to relief beyond mere possibility)
- McCauley v. City of Chicago, 671 F.3d 611 (7th Cir. 2011) (pleadings must state plausible claims at the pleading stage)
- Atkins v. City of Chicago, 631 F.3d 823 (7th Cir. 2011) (pleadings must show plausible, non-conclusory facts supporting claims)
- Wheeler v. Wexford Health Sources, Inc., 689 F.3d 680 (7th Cir. 2012) (advises limiting joinder when it risks confusion; may require separate complaints)
- Lee v. Clinton, 209 F.3d 1025 (7th Cir. 2000) (illustrates fantasy/implausibility principles; potential exceptions to general plausibility)
