Middleton v. Uhaul Company, 4:23-cv-00361

Plaintiff, Delano A. Middleton, filed multiple pro se federal cases (and one removed state action) in the Southern District of Georgia, mostly related to an altercation at a Savannah U-Haul involving his arrest and subsequent prosecution, plus another case relating to an airport arrest.
Middleton initially failed to prosecute his cases and did not respond to court orders, leading the court to require him to show cause to avoid dismissal; after eventually responding and explaining his inability to receive mail, the Court vacated dismissals based on abandonment.
The court then evaluated the substantive merits of each complaint, many of which repeated the same factual allegations or were duplicative, and all raising claims under 42 U.S.C. § 1983 for alleged constitutional violations.
Middleton's pleadings were repeatedly found deficient: they either failed to identify a legal entity as a defendant, were impermissible shotgun pleadings, or named defendants with immunity (the State of Georgia, district attorneys, public defenders).
One case was dismissed as time-barred (statute of limitations expired), others as duplicative or because amendment would be futile, and one because service could not be effectuated due to the non-existence of the named entity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to identify a suable defendant entity	U-Haul Corporation existed as a suable entity	U-Haul Corporation is not a legal entity	Dismissed; no such legal entity exists
Shotgun pleading/Failure to specify claims	Enthusiastic recitation of grievances against all	Pleadings too vague; claims not clearly asserted	Dismissed; did not satisfy pleading standards
Duplicative and malicious litigation	Different co-conspirators or additional facts	Claims are substantially identical/duplicative	Dismissed; cases duplicative, amendment futile
Claims against immune defendants and time-barred	State, DA, public defenders liable, no tolling	State and DA immune; no basis for tolling; time barred	Dismissed; barred by immunity or limitations

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for federal complaints, requiring non-conclusory factual allegations to state a claim)
Will v. Mich. Dep’t of State Police, 491 U.S. 58 (1989) (states are not persons under § 1983 and cannot be sued for damages thereunder)
Tower v. Glover, 467 U.S. 914 (1984) (public defenders are not typically state actors under § 1983 unless alleged to conspire with state actors)
Leal v. Ga. Dep't of Corr., 254 F.3d 1276 (11th Cir. 2001) (standard on screening under the PLRA is analogous to Rule 12(b)(6))
Curtis v. Citibank, 226 F.3d 133 (2d Cir. 2000) (district courts may dismiss duplicative federal suits as a matter of docket control)
Owens v. Fulton County, 877 F.2d 947 (11th Cir. 1989) (Georgia district attorneys are state officials and eligible for Eleventh Amendment immunity)