Niederstadt v. Lincoln County Detention Center, 2:22-cv-00749

Plaintiff Charles A. Niederstadt, formerly detained at Lincoln County Detention Center (LCDC), proceeded pro se and filed multiple handwritten letters and narrative complaints alleging constitutional and tort claims arising from his arrest and detention.
He filed an initial IFP motion (Oct. 7, 2022), a state-court formatted complaint, later narrative complaints adding multiple defendants, a Motion to Amend (Mar. 24, 2023), and a Motion to Show Cause (Apr. 12, 2023).
Pleadings alleged federal and/or state constitutional violations, false arrest, and tort claims against LCDC, private operator Correctional Solutions Group, Lincoln County officials, and various individuals.
Because Plaintiff was incarcerated when the suit began, the complaint is subject to screening under 28 U.S.C. § 1915A; the court found the filings unclear and not a short, plain statement as required by Rule 8.
The Court granted leave to proceed in forma pauperis, waived the initial partial payment, set a $350 fee payable in installments (20% monthly of preceding month’s income when balance exceeds $10, beginning Oct. 1, 2023), and ordered Plaintiff to file a single amended prisoner civil rights complaint on the court’s form within 30 days.
The Court denied the Motion to Amend and Motion to Show Cause as moot and directed the Clerk to mail the prisoner civil-rights complaint form to Plaintiff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency/clarity of pleadings	Filed multiple narrative complaints and letters alleging constitutional and tort claims against many defendants	No meaningful defense presented; pleadings are scattered	Court: pleadings are unclear, fail Rule 8; Plaintiff must file a single amended complaint on the court form
In forma pauperis (IFP) eligibility	Cannot prepay $402 filing fee; requests IFP	No opposition recorded	Court: IFP granted; initial partial payment excused; total reduced to $350; monthly payments of 20% of preceding month’s income when balance > $10 starting Oct. 1, 2023
Motions to Amend / Show Cause	Seeks to add defendants and claims (new individuals, false arrest)	No opposition recorded	Court: Motions denied as moot; claims must be clarified in single amended complaint
Nature of civil‑rights claims (federal §1983 vs NM Civil Rights Act)	Pleadings ambiguous as to whether claims arise under federal or state law	No opposing argument; court must determine proper jurisdictional basis	Court: Plaintiff must state whether claims are under §1983 or the New Mexico Civil Rights Act; court provided legal overview and required clarification

McNamara v. Brauchler, [citation="570 F. App'x 741"] (10th Cir. 2014) (court will not construct claims for pro se litigant)
West v. Atkins, 487 U.S. 42 (1988) (elements of a § 1983 claim and state-actor requirement)
McLaughlin v. Bd. of Trs. of State Colls. of Colo., 215 F.3d 1168 (10th Cir. 2000) (§ 1983 claim elements reaffirmed)
Trask v. Franco, 446 F.3d 1036 (10th Cir. 2006) (individual liability requires each official’s own actions)
Fogarty v. Gallegos, 523 F.3d 1147 (10th Cir. 2008) (connection between official conduct and constitutional violation required)
Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008) (complaint must identify who did what to whom)
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires official policy or custom)
Brammer-Hoelter v. Twin Peaks Charter Acad., 602 F.3d 1175 (10th Cir. 2010) (local entity liability cannot rest on respondeat superior)
Schneider v. City of Grand Junction Police Dep't, 717 F.3d 760 (10th Cir. 2013) (what constitutes official policy or custom for § 1983 purposes)