Ronnie Nicholson v. Scott Eckstein, 686 F. App'x 372

Ronnie Nicholson, a Wisconsin inmate, alleged that two Redgranite prison employees (Eckstein and Miller) seized or destroyed ~180 pages of his legal papers in 2007 that related to a 1999 Tennessee prison riot and his resulting skin injury.
Nicholson claims the loss of those papers prevented him from filing a timely § 1983 suit against the persons allegedly responsible for the riot and his chemical leukoderma.
District court screened and dismissed Nicholson’s complaint for failure to state a claim under 28 U.S.C. § 1915A, concluding Nicholson suffered no actionable prejudice because he could have filed suit based on personal knowledge or using placeholders for unknown defendants.
Nicholson moved to amend, asserting the missing documents contained critical details (names, dates, times); the district court rejected this and noted discovery and judicial tools could have identified defendants post-filing.
The Seventh Circuit affirmed, holding Nicholson failed to plausibly allege that loss of the papers prevented him from pursuing a legitimate claim; the court also noted the underlying Tennessee-based § 1983 claim would have been time-barred and that the appeal is frivolous (constituting a second § 1915(g) strike).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether confiscation/destruction of legal papers denied Nicholson meaningful access to courts	Loss of documents prevented timely suit against riot perpetrators and therefore denied access	Nicholson could have filed a complaint using his own knowledge or placeholder defendants and used discovery to get details	Court: No plausible prejudice; Nicholson could have filed and later obtained details — claim fails
Whether Rule 8 pleading standards require all factual details before filing	Needed the documents because they contained names, dates, times essential to state claim	Rule 8 only requires a short, plain statement; notice pleading suffices	Court: Rule 8/notice pleading means missing documents were not indispensable
Whether statute of limitations saved Nicholson’s underlying Eighth Amendment claim	Delay caused by defendants’ alleged concealment prevented timely filing	Even without concealment, the underlying claim accrued earlier and would be time-barred under Tennessee law	Court: Under Tennessee’s one-year limitations, the underlying claim expired well before 2007
Whether appeal was frivolous and counts as a strike under § 1915(g)	Nicholson pursued appeal claiming deprivation of access to courts	Defendants argued appeal lacked merit	Court: Appeal frivolous; constitutes second § 1915(g) strike

Ortiz v. Downey, 561 F.3d 664 (7th Cir. 2009) (access-to-courts claim requires plausible showing of prejudice to a nonfrivolous suit)
Marshall v. Knight, 445 F.3d 965 (7th Cir. 2006) (same — elements of access-to-courts claim)
United States ex rel. Hanna v. City of Chicago, 834 F.3d 775 (7th Cir. 2016) (Rule 8 notice-pleading standard explained)
Billman v. Ind. Dep’t of Corr., 56 F.3d 785 (7th Cir. 1995) (use of placeholder defendants to preserve claims)
Brown v. Owens Corning Inv. Review Comm., 622 F.3d 564 (6th Cir. 2010) (plausibility of claims and amendment practice)
Bryant v. City of Chicago, 746 F.3d 239 (7th Cir. 2014) (judicial assistance and identification of unknown defendants)
Donald v. Cook Cty. Sheriff’s Dep’t, 95 F.3d 548 (7th Cir. 1996) (procedures for identifying unknown defendants)
King v. One Unknown Fed. Corr. Officer, 201 F.3d 910 (7th Cir. 2000) (statute of limitations borrowing rule in § 1983 cases)
Cesal v. Moats, 851 F.3d 714 (7th Cir. 2017) (application of limitations period in § 1983 claims)
Johnson v. Memphis Light Gas & Water Div., 777 F.3d 838 (6th Cir. 2015) (Tennessee one-year statute of limitations for § 1983 claims)