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