Sadler v. State of Montana, 1:17-cv-00699

Plaintiff Timothy Ray Sadler (pro se) filed a civil rights "Complaint" seeking wide-ranging relief and naming numerous varied defendants (states, military, organizations, and individuals) and alleging conspiracies, enhancements, and crimes against him.
Sadler indicated an intention to proceed in the International Court of Justice, but mailed the Complaint to the U.S. District Court for the District of New Mexico.
The Complaint contained no specific factual allegations tying any named government official to any particular constitutional violation; it instead listed many defendants and broad, delusional conspiracy assertions.
The Court screened the Complaint under 28 U.S.C. § 1915(e)(2)(B) and Fed. R. Civ. P. 12(b)(6) because Sadler appeared to seek in forma pauperis status.
The Court found the pleading legally insufficient (no § 1983 allegations of individual conduct or constitutional deprivation) and frivolous (delusional, baseless allegations).
The Court dismissed the Complaint with prejudice (no leave to amend) as amendment would be futile and the Court likely lacked jurisdiction over many purported defendants outside New Mexico.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Complaint states a plausible § 1983 claim	Sadler broadly alleges worldwide conspiracy, crimes, and enhancements against him by many entities	Implicit defense: complaint fails to plead specific actions by state actors or constitutional violations	Dismissed for failure to state a claim; no individualized acts or constitutional deprivation pleaded
Whether the Complaint is frivolous under § 1915(e)(2)(B)	Plaintiff advanced expansive, delusional allegations purportedly verifiable worldwide	Court may dismiss baseless, clearly delusional claims sua sponte	Court held claims are frivolous and clearly delusional; dismissal appropriate
Whether court should grant leave to amend	Plaintiff did not present focused, factual allegations against New Mexico defendants	Defendants (and court) note defect is substantive and likely incurable; jurisdictional problems exist	Leave to amend denied as futile; amendment would not cure legal defects or jurisdictional barriers
Whether plaintiff adequately named/connected officials for § 1983 liability	Plaintiff named thousands of entities but made no individual-specific allegations	§ 1983 requires each official’s personal involvement to be alleged	Court held complaint failed to identify who did what; § 1983 claims insufficient

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim to survive dismissal)
Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous complaint standard for § 1915 screening)
Denton v. Hernandez, 504 U.S. 25 (1992) (court may pierce pleadings and dismiss baseless claims under § 1915)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (must plead facts showing each defendant’s individual liability)
Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (pro se pleadings are liberally construed but still must meet legal standards)
Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008) (complaint must show who did what to whom to provide fair notice)
West v. Atkins, 487 U.S. 42 (1988) (§ 1983 applies to state actors acting under color of law)
Trask v. Franco, 446 F.3d 1036 (10th Cir. 2006) (conduct must be connected to constitutional violation for § 1983 liability)
Fogarty v. Gallegos, 523 F.3d 1147 (10th Cir. 2008) (personal involvement required for § 1983 claims)
Reynoldson v. Shillinger, 907 F.2d 124 (10th Cir. 1990) (pro se plaintiffs should be allowed to amend unless amendment is futile)