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Jurijus Kadamovas v. Michael Stevens
706 F.3d 843
| 7th Cir. | 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Jurijus Kadamovas v. Michael Stevens
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Feb 7, 2013
Citation: 706 F.3d 843
Docket Number: 12-2669
Court Abbreviation: 7th Cir.