Sparks v. Danbury Superior Court, 3:22-cv-00844

Pro se plaintiff Tod M. Sparks, II filed suit December 29, 2021 against the Superior Court of Danbury, judges, clerks, and police, alleging they permitted Diana Clarke to stalk and sexually harass him and that the court was negligent in failing to prevent it.
Sparks described stalking by internet, cellphone, third parties, drive-bys, and repeated calls to police; he said he and his family felt unsafe.
Sparks moved to proceed in forma pauperis (granted by separate order). The court screened the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii).
The court found no basis for federal jurisdiction: Sparks failed to plead diversity (no citizenships or amount in controversy) and did not identify any federal constitutional claim.
The court concluded Sparks’s pleading also failed Rule 8’s short-and-plain-statement requirement and did not allege elements of negligence or any § 1983 constitutional violation.
The court dismissed the complaint for lack of jurisdiction and failure to state a claim but granted Sparks 30 days’ leave to file an amended complaint curing the deficiencies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction (federal question / diversity)	Sparks invoked diversity jurisdiction against the Superior Court of Danbury and others	Defendants (and court on screening) noted Sparks did not plead parties’ citizenships or amount in controversy and asserted no federal question	Dismissed for lack of subject-matter jurisdiction; jurisdiction not established
Failure to plead a constitutional claim under § 1983	Sparks alleged negligence and generalized harm from stalking/harassment	Complaint did not identify any constitutional right or specific conduct giving rise to a § 1983 claim	Dismissed for failure to state a federal constitutional claim under Rule 8
Sufficiency of negligence claim	Sparks asserted Superior Court was negligent in preventing stalking/harassment	Complaint did not allege duty, breach, causation, or specific damages sufficient for a negligence claim	Negligence allegations insufficient to state a claim; negligence does not substitute for a § 1983 claim
Leave to amend	Sparks requested relief in original filing	Court must consider liberal construction for pro se plaintiffs but may deny futile amendments	Court granted leave to file an amended complaint within 30 days to attempt to cure pleading defects

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading requires more than labels and conclusions)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (courts need not credit threadbare recitals of elements)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are liberally construed)
Grayson v. Mayview St. Hosp., 293 F.3d 103 (3d Cir. 2002) (district court must permit curative amendment unless futile)
Palakovic v. Wetzel, 854 F.3d 209 (3d Cir. 2017) (plausibility standard for pleading)
Burtch v. Milberg Factors, Inc., 662 F.3d 212 (3d Cir. 2011) (12(b)(6) standard explained)
Tellabs, Inc. v. Makor Issues & Rts., Ltd., 551 U.S. 308 (2007) (court may consider documents incorporated by reference)
Schuchardt v. President of the U.S., 839 F.3d 336 (3d Cir. 2016) (presumption of truth applies only to plausible allegations)
McCann v. Newman Irrevocable Tr., 458 F.3d 281 (3d Cir. 2006) (diversity jurisdiction requirements)