Trent Griffin, Sr. v. American Zurich Insurance Co
697 F. App'x 793
| 5th Cir. | 2017Background
- Pro se plaintiff Trent S. Griffin sued multiple defendants (American Zurich; Walgreens and employees; Wells Fargo; various Texas state agencies and employees) alleging a broad conspiracy leading to adverse employment actions, a denied insurance/benefits determination, foreclosure of his home, garnishment of veteran’s benefits, and disputes related to child support/custody.
- Griffin filed multiple pleadings and amended complaints; defendants moved to dismiss; the district court ordered a new amended complaint and later dismissed all claims against each defendant group, entering final judgment for defendants.
- The district court dismissed claims on grounds including res judicata (American Zurich), failure to plead ADA disability details (Walgreens), judgment on the pleadings for Wells Fargo (foreclosure and garnishment claims), and immunity/Rooker–Feldman/ failure-to-state-a-claim for State Defendants.
- Griffin moved for new trials (denied) and appealed the dismissals and various docket-management decisions; he argued the court failed to liberally construe his pro se filings and mishandled motions.
- The Fifth Circuit reviewed dismissal de novo, and abuse-of-discretion for docket management, and affirmed, holding the district court sufficiently construed pro se filings, applied appropriate procedural rules, and correctly dismissed each set of claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| District court’s docket management | Griffin: court failed to liberally construe pro se filings and abused discretion in refusing/striking/amending motions | Defendants: court properly managed filings, granted leave to amend, and motions became moot or timely after refiling | Affirmed — court liberally construed filings and did not abuse discretion |
| Claim preclusion re: American Zurich | Griffin: dismissal erroneous; claims not precluded | Zurich: prior state-court final judgment bars relitigation | Affirmed — res judicata applies under Texas law; parties/claims identical |
| ADA disability claim against Walgreens | Griffin: asserts ADA violation | Walgreens: complaint lacks facts showing major life activity substantially limited | Affirmed — pleadings are conclusory; no facts showing substantial limitation |
| Wells Fargo foreclosure and garnishment claims | Griffin: wrongful foreclosure; improper liens/garnishment without notice | Wells Fargo: procedures/law do not support Griffin’s allegations; pleading defects on foreclosure elements | Affirmed — judgment on pleadings proper; foreclosure claim inadequately pleaded |
| Claims vs. State Defendants (immunity, §5301, Rooker–Feldman) | Griffin: garnishment of veteran benefits unlawful; procedural/service errors | State: immunity applies; §5301 does not bar child-support garnishment; Rooker–Feldman bars federal relitigation of state-court orders; service improper for one defendant | Affirmed — immunity/previous state rulings control; §5301 inapplicable to child-support garnishment; service defective for Rivera |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard requires more than conclusory statements)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Chhim v. Univ. of Tex. at Austin, 836 F.3d 467 (pro se plaintiffs held to liberal but realistic pleading standard)
- Villarreal v. Wells Fargo Bank, N.A., 814 F.3d 763 (elements for wrongful foreclosure in Texas)
- Martins v. BAC Home Loans, L.P., 722 F.3d 249 (foreclosure inadequacy and causation requirements)
- Rose v. Rose, 481 U.S. 619 (§5301 does not shield veteran benefits from child-support garnishment)
- Mansell v. Mansell, 490 U.S. 581 (domestic-relations matters remain governed by state law)
- Jones v. Greninger, 188 F.3d 322 (conversion of a dismissal motion to judgment on the pleadings)
- Cox v. Nueces Cty., 839 F.3d 418 (res judicata principles and choice-of-law for preclusion)
- Hale v. King, 642 F.3d 492 (ADA claim dismissal where plaintiff fails to plead major life activity limitations)