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Staples v. USA
1:17-cv-00328
W.D. La.
Aug 28, 2017
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Background

  • Staples is an inmate in BOP custody who filed a pro se complaint against federal officers under Bivens and FTCA.
  • He challenges disciplinary convictions imposed while housed at USP-Pollock, Louisiana, including July 2010 assault and related sanctions.
  • He also challenges February 2011 incident reports for medication misuse and count violations, with corresponding sanctions.
  • A later, unspecified date allegedly involved a refused-order incident report resulting in commissary loss.
  • Several disciplinary convictions were expunged after Staples served the sanctions; the expungements are noted in the record.
  • The court screened the complaint under 28 U.S.C. § 1915A and found it duplicative of a prior suit, 1:16-cv-1284, addressing the same events and claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the complaint is frivolous or fails to state a claim under § 1915A. Staples contends his claims have merit and should proceed. The complaint lacks plausible legal or factual basis and is duplicative. Frivolous/insufficient for failure to state a claim.
Whether the action is duplicative of a pending suit. Staples asserts distinct grounds for relief in separate filings. The claims arise from the same events as 1:16-cv-1284 and are duplicative. Duplicative; recommended dismissal without prejudice to the pending case.

Key Cases Cited

  • Neitzke v. Williams, 490 U.S. 319 (U.S. 1989) (frivolousness standard for § 1915A screening)
  • Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for pleading claims)
  • Iqbal v. Ashcroft, 556 U.S. 662 (U.S. 2009) (pleading must state plausible claims)
  • Bailey v. Johnson, 846 F.2d 1019 (5th Cir. 1988) (discusses dismissal when claims arise from same events)
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Case Details

Case Name: Staples v. USA
Court Name: District Court, W.D. Louisiana
Date Published: Aug 28, 2017
Docket Number: 1:17-cv-00328
Court Abbreviation: W.D. La.