Wyley v. Cuyahoga County
1:25-cv-00230
N.D. OhioJun 4, 2025Background
- Asia Wyley, proceeding pro se, sued Cuyahoga County, challenging her arrest, detention in the county jail, and subsequent criminal conviction.
- Wyley alleged she was denied disability accommodations and subjected to inhumane jail conditions (held naked, deprived of water, food, hygiene).
- She claimed her constitutional rights were violated in retaliation for possessing information about county officials and accused the county of fabricating evidence against her.
- Wyley’s complaint invoked multiple constitutional amendments and the ADA but lacked specific facts supporting these claims.
- She sought over $111 billion in damages and other relief.
- The Court granted her motion to proceed in forma pauperis but reviewed the complaint for legal sufficiency under 28 U.S.C. § 1915(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of allegations | Wyley claimed discrimination, rights violations, and harms | Not specified | Dismissed: Complaint did not state facts sufficient to state a plausible claim |
| Constitutional claims under § 1983 | Violations of various amendments | Not specified | Dismissed: No facts alleged linking county policy/custom to alleged violations |
| ADA claim | County failed to provide disability accommodations | Not specified | Dismissed: No facts pleaded regarding nature of disability or denial of accommodation |
| Damages claim against municipality | Sought damages for constitutional violations | Not specified | Dismissed: No showing of Monell liability or municipal policy/custom |
Key Cases Cited
- Boag v. MacDougall, 454 U.S. 364 (standard for liberal construction of pro se pleadings)
- Haines v. Kerner, 404 U.S. 519 (pro se filings construed liberally)
- Neitzke v. Williams, 490 U.S. 319 (establishing dismissal standard for frivolous or baseless claims)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)
- Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability under § 1983)
- Wyatt v. Cole, 504 U.S. 158 (purpose and scope of § 1983)