Sharp v. South Carolina Department of Social Services (DSS), 3:25-cv-01203

Plaintiff Deanna Sharp brought suit under 42 U.S.C. § 1983 challenging the removal of her disabled son by South Carolina DSS and her related criminal charge.
The complaint included multiple public agencies, law enforcement personnel, school districts, and other individuals, alleging failures related to the accommodation of her son’s disability and other harms.
Plaintiff was ordered to cure procedural deficiencies in her filings and amend her complaint to address legal defects.
Despite extensions and multiple filings, Plaintiff failed to comply fully with the court’s proper form order or to state a legally sufficient claim.
Magistrate Judge recommended summary dismissal for both procedural noncompliance and failure to state a claim, as well as denial of various emergency and preliminary motions.
The District Court adopted the recommendation, dismissing the action without prejudice and denying all pending motions.

Issue	Plaintiff's Argument	Defendant's Argument (summarized by the court)	Held
Failure to comply with procedural orders	Sharp claimed she attempted compliance and that filing difficulties stemmed from disability and lack of court staff assistance.	Plaintiff did not cure defects or fully comply.	Dismissal under Rule 41(b) for noncompliance.
Failure to state a claim under § 1983	Claimed multiple constitutional and statutory violations (ADA, IDEA, FERPA), conclusory stated, relating to her son's removal and denial of accommodations.	Defendants included unsuable entities/no factual link.	Dismissal; allegations were conclusory and legally insufficient under Iqbal/Twombly.
Motions for emergency/protective relief	Requested emergency return/protection for her son, federal protection, and immediate relief based on alleged ongoing harm.	Plaintiff did not have a likelihood of success.	Denied; insufficient grounds and much relief outside federal authority (domestic relations exception applies).
Motions to amend, seal, and for reassignment	Sought to further amend (beyond right), seal specific records, remove judge, and reassign the case, citing bias and protecting her son's privacy and safety.	Proposed amendments and requests remain deficient or moot.	Denied as futile or moot; no prejudice, futility in amendments, no evidence of bias.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard requires more than conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for stating a claim)
Mathews v. Weber, 423 U.S. 261 (1976) (district judge makes final determinations on magistrate recommendations)
Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005) (standard for district court review of magistrate judge recommendations)
Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990) (liberal construction for pro se litigants, but not to ignore pleading defects)