Vaughn v. Common Pleas Court of Montgomery County Ohio, 3:16-cv-00248

In 1974 Grace Vaughn and her female partner applied for a marriage license in Montgomery County, Ohio and were denied because both applicants were female.
They sued in the Montgomery County Court of Common Pleas; the state court concluded Ohio law required spouses to be of different sexes and entered judgment for the defendant in 1975.
In 2016 Vaughn filed a federal pro se complaint seeking $100,000,000, alleging constitutional civil‑rights violations and emotional distress from denial of the marriage license.
The only named defendant in the federal complaint is the Montgomery County Court of Common Pleas (a state court).
The magistrate judge conducted an initial review under 28 U.S.C. § 1915(e)(2), accepting pro se allegations as true and construing them liberally.
The magistrate recommended dismissal because the constitutional right now asserted (to same‑sex marriage) was not recognized in 1975 and because a state court is not a "person" under § 1983 and thus cannot be sued.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 1974 denial violated a federal constitutional right	Vaughn contends denial of marriage license to two women violated her civil rights under the U.S. Constitution	Historically, Ohio law and the state court held marriage requires different sexes; court availability of the federal right was not recognized in 1975	Dismissed: no cognizable § 1983 claim because the constitutional right to same‑sex marriage was not established until Obergefell (2015)
Whether the Court of Common Pleas is a proper § 1983 defendant	Vaughn sued the Montgomery County Court of Common Pleas as the defendant responsible for the denial	The court (and case law) treat courts as not being "persons" under § 1983 and thus not sui juris defendants	Dismissed: state court is not a "person" under § 1983 and lacks capacity to be sued
Whether the complaint is frivolous or fails to state a claim under § 1915(e)(2)	Vaughn's factual allegations are genuine and seek relief for past harm	Legal basis is absent because the asserted federal right did not exist in 1975; defendant is immune/non‑person	Dismissed as legally frivolous under § 1915(e)(2)
Whether appeal would be taken in good faith	Vaughn likely would seek appellate review	The magistrate judge evaluated merits under § 1915(a)(3)	Certified that any appeal would not be taken in good faith

Obergefell v. Hodges, 135 S. Ct. 2584 (U.S. 2015) (recognized constitutional right to same‑sex marriage)
Neitzke v. Williams, 490 U.S. 319 (1989) (standards for dismissing frivolous complaints)
Brand v. Motley, 526 F.3d 921 (6th Cir. 2008) (frivolous complaint lacks arguable basis in law or fact)
Williams v. Curtin, 631 F.3d 380 (6th Cir. 2011) (pro se complaints are to be liberally construed)
Shadrick v. Hopkins Cty., Ky., 805 F.3d 724 (6th Cir. 2015) (elements required for a § 1983 claim)
Jones v. Muskegon Cnty., 625 F.3d 935 (6th Cir. 2010) (§ 1983 causation and state action requirements)
Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990) (allegations that are fantastic or delusional can support dismissal)