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Marcus Murphy appealed the district court’s order dismissing his 42 U.S. Code 1983 complaint. Because the district court didn’t abuse its discretion in concluding Murphy’s complaint was too conclusory and vague to comply with Federal Rule of Civil Procedure 8, the 10th Circuit Court of Appeals affirmed.
Murphy alleged violations of his rights under the Fourth, Fifth, Sixth, Seventh, Eighth and 14th Amendments and named as defendants 10 individuals affiliated with a Colorado sheriff’s office and county court. The operative second amended complaint alleged sheriff’s deputies, in violation of a court order for a stay of eviction, wrongfully entered Murphy’s home; assaulted, searched and arrested him; and damaged his property. Murphy also alleged during his time in the county jail, deputies and other individuals left him bleeding and abandoned; denied him lunch, dinner and medication; and prevented him from meeting with his public defender and accessing discovery materials. Additionally, Murphy asserted his bail was excessive and his speedy-trial rights had been violated.
The magistrate judge recommended dismissing Murphy’s claims as inadequately pleaded under Rule 8 and barred by the abstention doctrine announced in Younger v. Harris. Murphy filed objections to the magistrate judge’s recommendation, but the district court overruled them, adopted the recommendation in full and dismissed Murphy’s claims without prejudice. Murphy appealed.
Murphy first challenged the district court’s dismissal of his 1983 claims pursuant to Rule 8. Rule 8(a)(2) provides “a pleading must contain a ‘short and plain statement of the claim showing that the pleader is entitled to relief,’” the opinion noted, citing the decision Ashcroft v. Iqbal. “The pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation,” the opinion added, citing the decision Bell Atl. Corp. v. Twombly. Similarly, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.”
Murphy conceded the district court “correctly recite[d]” his “simple [and] concise” allegations. But he contended it abused its direction in concluding those allegations didn’t satisfy Rule 8.
After evaluation, the 10th Circuit affirmed the district court’s order dismissing Murphy’s complaint without prejudice because it didn’t abuse its discretion in determining Murphy’s allegations were too vague and conclusory to satisfy Rule 8.
The 10th Circuit also granted Murphy’s IFP motion and denied his motion to seal.