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Singh v. Kauffman

United States District Court, M.D. Pennsylvania

April 19, 2018

RYAN PAUL SINGH, Plaintiff,
v.
KEVIN KAUFFMAN, Defendant.

          MEMORANDUM OPINION

          Matthew W. Brann United States District Judge

         I. BACKGROUND

         Ryan Paul Singh, an inmate confined at the State Correctional Institution, Huntingdon, Pennsylvania (SCI-Huntingdon) initiated this pro se civil rights action pursuant to 42 U.S.C. § 1983. The required filing fee has been paid. For the reasons set forth below, Singh's action will be dismissed, without prejudice, as legally frivolous pursuant to the screening provisions of 28 U.S.C. § 1915A.

         Named as sole Defendant is SCI-Huntingdon Superintendent Kevin Kauffman. Plaintiff describes himself as being a real party in interest, third party intervenor, and secured party creditor. Singh vaguely contends that his ongoing incarceration is the result of illegal actions undertaken by Lancaster County, Pennsylvania officials. The Complaint appears to allege that Singh's state criminal prosecution and resulting commitment order violated maritime law and the Uniform Commercial Code. As relief, Plaintiff seeks his immediate release from prison. See Doc. 1, ¶ V.

         II. DISCUSSION

         Title 28 U.S.C. § 1915A provides in pertinent part:

(a) Screening. -- The court shall review ... a complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity.
(b) Grounds for dismissal. -- On review, the court shall identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint -
(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or
(2) seeks monetary relief from a defendant who is immune from such relief.

         A district court may rule that process should not be issued if the complaint is malicious, presents an indisputably meritless legal theory, or is predicated on clearly baseless factual contentions. Neitzke v. Williams, 490 U.S. 319, 327-28 (1989); Douris v. Middleton Township, 293 Fed.Appx. 130, 132 (3d Cir. 2008).

         Indisputably meritless legal theories are those “in which either it is readily apparent that the plaintiff's complaint lacks an arguable basis in law or that the defendants are clearly entitled to immunity from suit ... .” Roman v. Jeffes, 904 F.2d 192, 194 (3d Cir. 1990) (quoting Sultenfuss v. Snow, 894 F.2d 1277, 1278 (11th Cir. 1990)).

         A. Personal Involvement

         A plaintiff, in order to state an actionable civil rights claim, must plead two essential elements: (1) that the conduct complained of was committed by a person acting under color of law, and (2) that said conduct deprived the plaintiff of a right, privilege, or immunity secured by the Constitution or laws of the United States. Groman v. Township of Manalapan, 47 ...


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