Jill Coit, a state prisoner at the Denver Women's Correctional Facility, filed a pro se complaint alleging sexual assault by a guard, subsequent cover-up, retaliation, and denial of medical and religious care. After multiple amendments, the district court dismissed her fourth amended complaint under 28 U.S.C. § 1915(e)(2)(B). The dismissal was based on two primary grounds: the Eleventh Amendment barred claims for money damages against defendants sued in their official capacities, and the complaint failed to state a plausible claim under Federal Rule of Civil Procedure 8 because it lacked sufficient factual matter. Coit appealed, arguing that her complaint should be construed liberally and that she had properly pled a claim against the deceased guard, who was not listed in the operative fourth amended complaint.
The Tenth Circuit reviewed the dismissal de novo, applying the same standard as a Rule 12(b)(6) motion. The court accepted well-pleaded allegations as true but required them to be plausible on their face. The court addressed Coit's seven appellate arguments, finding them unavailing. First, the court noted that Coit's claim against Sergeant Lang could not be heard because he was not named in the fourth amended complaint, which the court treated as the operative pleading. Second, the court rejected the argument that earlier complaints should be incorporated by reference, citing the magistrate judge's specific order requiring a single, fully completed complaint containing all allegations. The court emphasized that judges are not required to search through multiple documents to find claims. Regarding the remaining issues, which involved claims for breach of contract, ADA violations, and constitutional rights, the court found that Coit failed to address the Eleventh Amendment immunity issue in her brief. Under Tenth Circuit precedent, if an appellant fails to challenge all alternative grounds for a ruling, the court may affirm. Finally, the court rejected the argument that her pro se status made the dismissal unfair, stating that such status does not excuse non-compliance with the Federal Rules of Civil Procedure.
The dismissal stands, barring Coit from litigating her current allegations under the fourth amended complaint. The court left her allegations regarding sexual assault and medical neglect unadjudicated on the merits but effectively closed the door on further litigation under the current pleadings. Coit remains obligated to pay partial filing fees, and the decision serves as a reminder that pro se litigants must strictly adhere to pleading rules and cannot rely on courts to construct their cases.
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