MITCHELL v. NEWARK HOUSING AUTHORITY, 2:25-cv-00445

Plaintiff Saad M. Mitchell Sr. alleged that a maintenance employee of the Newark Housing Authority let police into his home without a warrant, leading to emotional distress.
The initial complaint was construed as a 42 U.S.C. § 1983 claim for violation of the Fourth Amendment (unreasonable search).
Plaintiff was granted leave to proceed in forma pauperis, triggering mandatory screening under 28 U.S.C. § 1915(e)(2)(B) for frivolousness and failure to state a claim.
Plaintiff amended his complaint, replacing the Newark Housing Authority with defendant Natalie Sharpe but did not clarify her role or involvement in the events.
The court reviewed the amended complaint sua sponte and found it deficient because it did not specify Sharpe’s personal involvement, a necessary aspect of a § 1983 claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does amended complaint state a § 1983 Fourth Amendment claim?	Defendant (Sharpe) responsible for allowing warrantless entry	Not specified, complaint was at screening	No, fails to allege defendant's personal involvement, so not plausible
Must complaint specify individual defendant's role?	Implicitly argues role is inferable	Not specified	Yes, clear personal involvement must be pled
Can pro se status excuse lack of specifics?	Pro se, entitled to liberal construction	Not specified	Pro se liberality helps, but specifics still required
Should leave to amend be granted?	Seeks relief for emotional damages	Not specified	Yes, given opportunity to replead within 45 days

Neitzke v. Williams, 490 U.S. 319 (defining "frivolous" for IFP screening)
Ashcroft v. Iqbal, 556 U.S. 662 (complaint must state a plausible claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
City of Canton, Ohio v. Harris, 489 U.S. 378 (municipal liability for constitutional violations)
Rode v. Dellarciprete, 845 F.2d 1195 (personal involvement requirement for § 1983 liability)