Rayford, Jr. v. Northwest Ohio Realtors, 3:25-cv-00380

Plaintiff Kibwe Rayford, Jr., proceeding pro se, filed numerous nearly identical employment discrimination lawsuits using a self-styled form complaint against various defendants, including Northwest Ohio Realtors.
In each complaint, Rayford claimed violations of Title VII, the ADA, and the EEOA, but provided no specific facts relating to any defendant or position beyond naming the employer and position applied for.
The complaints lacked individualized factual allegations and consisted almost entirely of legal conclusions and unchecked boxes listing various forms of discrimination.
The specific complaint against Northwest Ohio Realtors alleged only that Rayford applied for an Office Manager job but did not provide dates or evidence supporting his application or alleged discrimination.
The Court noted a pattern of frivolous, repetitive litigation by Rayford, with over twenty similar cases pending and multiple motions filed containing no case-specific facts.
The case reached the federal court through removal by defendants, and the Court reviewed the complaint sua sponte for sufficiency under federal pleading standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Complaint for Discrimination	Defendant failed to hire due to unlawful reasons; only evidence is denial of interview/job after applying and being “overqualified.”	Complaint lacks sufficient factual basis	Complaint dismissed as frivolous; does not meet basic pleading standards.
Entitlement to Relief under Federal Statutes	Rayford presumed discrimination occurred because of membership in protected classes and not being selected.	No specific argument (defendant not required to respond at this stage).	No plausible claim; failure to hire alone, without specifics, is not actionable.
Adequacy of Pro Se Pleading	Rayford’s complaint should be construed liberally.	Court questions entitlement to liberal construction due to Rayford’s legal education.	Even liberally construed, the complaint fails to state a claim.
Filing Vexatious or Frivolous Litigation	No direct argument; continued repetitive filings.	Argued through court observation; repeated frivolous filings.	Plaintiff enjoined from further filings in this case; pattern deemed vexatious.

Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are subject to less stringent pleading standards)
Neitzke v. Williams, 490 U.S. 319 (1989) (complaints can be dismissed if frivolous or lacking legal basis)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim for relief)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must have factual enhancement, not just conclusory statements)
Apple v. Glenn, 183 F.3d 477 (6th Cir. 1999) (court may dismiss frivolous complaints sua sponte)