Rayford, Jr. v. Impact Employment Solutions, 3:25-cv-00366

Kibwe Rayford, Jr., acting pro se, filed dozens of nearly identical employment discrimination complaints in Ohio state and federal courts, including against Impact Employment Solutions.
Each complaint is a form with only the job title, company, and application dates changed; the substance and causes of action are otherwise identical and lack specific factual allegations.
Rayford alleges he was not hired despite meeting qualifications and lists discrimination based on race, color, gender, national origin, disability, and education.
The complaints routinely cite Title VII, ADA, and other anti-discrimination statutes but lack any particularized facts linking alleged conduct to each defendant.
The District Court noted Rayford’s filings are vexatious and lack factual basis, viewing them as either misguided attempts to generate income via litigation or harassment.
Rayford had previously been enjoined from further filings without leave of court, yet continued submitting repetitive motions and complaints, leading to a filing ban in this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Complaint Under Rule 8	Rayford claims he was denied employment based on protected status, citing broad anti-discrimination statutes.	Complaint lacks facts or valid legal claim; is frivolous and vague.	Dismissed. Complaint does not meet minimal pleading standards.
Propriety of Repeated, Identical Filings	Repeated filings are valid attempts to seek redress.	Filings are vexatious, harassing, and frivolous.	Plaintiff’s conduct is vexatious and improper; filings enjoined.
Leave to File Further Motions	Seeks permission via form motion using statutory excerpts.	Motions lack merit, contain no facts, and ignore court’s prior orders.	Leave denied; further motions/documents barred in case.
Appeal in Forma Pauperis	Would be entitled to appeal dismissal.	Appeal would be frivolous; not in good faith.	Court certifies no good faith basis for appeal.

Haines v. Kerner, 404 U.S. 519 (pro se complaints held to less stringent standards)
Neitzke v. Williams, 490 U.S. 319 (dismissal proper where complaint is frivolous or lacks an arguable basis in law)
Apple v. Glenn, 183 F.3d 477 (court may dismiss complaints sua sponte if allegations are implausible or frivolous)
Twombly, 550 U.S. 544 (complaint must state plausible claim to relief; legal conclusions alone insufficient)
Ashcroft v. Iqbal, 556 U.S. 662 (pleadings must contain factual matter sufficient to state plausible claim)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (no heightened pleading standard for employment discrimination claims)