Terrance Godfrey v. Bryan Easton
702 F. App'x 469
| 7th Cir. | 2017Background
- Terrance Godfrey, an Illinois prisoner, sued Menard Correctional Center officials under 42 U.S.C. § 1983 alleging guards beat him; he filed a lengthy form complaint with nearly 200 pages of attachments.
- The district court dismissed the complaint without prejudice on June 14, 2016 under Fed. R. Civ. P. 8(a)(3) because the form complaint’s “REQUEST FOR RELIEF” box was left blank and the court concluded there was "no request for relief."
- The court instructed Godfrey to amend by July 15; Godfrey moved for copies and later for an extension, explaining he was transferred between prisons and had limited law-library access and delayed receipt of the order.
- On August 16, 2016 the court dismissed the case with prejudice for failure to comply with the June 14 order, reasoning Godfrey had not addressed the deficiency and was an experienced pro se litigant.
- On appeal, Godfrey contended he did not understand he needed to state a specific amount/form of relief and that his pro se status and limited access justified relief.
- The court of appeals found a handwritten “VI. Prayer for Relief” page buried about 160 pages into the submission requesting $15 million (and alternatively $10 million) against each defendant; it held that Rule 8 was satisfied and that dismissal for failure to specify relief was improper under controlling precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint failed to contain a demand for relief under Rule 8(a)(3) | Godfrey: pro se filing, limited access, unaware he had to state amount or form precisely | District court: the form’s relief box was blank so complaint contained no request for relief | Reversed: a handwritten “Prayer for Relief” attached sufficed to satisfy Rule 8(a)(3) and give notice to defendants |
| Whether dismissal with prejudice for failure to comply was warranted given alleged lack of notice/limited access | Godfrey: delayed receipt of order, limited law-library access, requested extension | District court: Godfrey received copies, had prior federal filings, and could have made a basic demand without law-library access | Reversed: even if no explicit demand, precedent bars dismissal for failure to specify relief; dismissal with prejudice was improper |
| Whether pro se status or disorganized filings excuse procedural defects | Godfrey: pro se and confused status limited ability to comply | District court: pro se experience meant Godfrey should know to demand relief | Court of appeals: pro se status and disorganization do not justify dismissal when pleadings provide notice; construing pleadings to do substantial justice applies |
| Proper interpretation of Rule 8 and related pleading principles | Godfrey: substantial justice and liberal construction should permit his pleading | District court: strict interpretation required a discrete demand in the form complaint | Court of appeals: apply Swierkiewicz and Rule 8(e)/(f)/54(c) principles; pleadings should be read to give notice and not dismissed when relief could be awarded under alleged facts |
Key Cases Cited
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (recognition that pleadings need only give fair notice and be construed to do substantial justice)
- Bontkowski v. Smith, 305 F.3d 757 (7th Cir. 2002) (failure to specify relief in pleadings does not justify dismissal; Rule 54(c) permits relief not demanded)