ERICSON v. SHERIFFS OF SOMERSET COUNTY JAIL et al

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UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
ERIC ERICSON,
Plaintiff,
v.
SHERIFFS OF SOMERSET
COUNTY JAIL, et al.,
Defendants.
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1:25-cv-00381-SDN
ORDER AFFIRMING RECOMMENDED DECISION
On January 7, 2026, the Magistrate Judge recommended dismissing Plaintiff Eric
Ericson’s complaint after preliminary review under 28 U.S.C. § 1915(e)(2). ECF No. 14
(“Recommended Decision”). Mr. Ericson objected to the Recommended Decision on
March 16, 2026, ECF No. 20, which the Court considers timely for the purposes of this
Order, see ECF No. 19. After de novo review of the Recommended Decision, the Court
AFFIRMS and ADOPTS the decision and DISMISSES the case.
BACKGROUND
On July 21, 2025, Mr. Ericson filed a complaint against several institutional
entities: the Sheriffs of Somerset County Jail, the Sheriffs of Cumberland County Jail, the
Sheriffs of Strafford County Jail, the wardens of the “federal transfer center,” the “federal
medical center,” the “federal trade center,” the Wyatt detention facility, the U.S. Marshals,
the “transportation deputies,” the “air police,” and the “air marshals.” ECF No. 1. He
subsequently amended his complaint to add defendants “Does 1–5” and Alternative
Correctional Healthcare in Brunswick, Maine. See ECF Nos. 11, 13. The complaint and
amended complaint generally allege that, while Mr. Ericson was a pretrial detainee in
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multiple jails, the Defendants denied his rights by failing to accommodate his disabilities,
interfering with his court and attorney access, and confiscating his personal property. See
ECF No. 1 at 3. He also asserts various Defendants assaulted him “to cover up their
crimes.” Id.
FAILURE TO STATE A CLAIM
Because 	Mr. 	Ericson 	proceeded 	in 	forma 	pauperis, 	the 	Magistrate 	Judge
conducted a preliminary review of the complaint and amended complaint to determine
whether they stated a claim on which relief could be granted. See 28 U.S.C. § 1915(e)(2).
The Magistrate Judge’s well-reasoned Recommended Decision 	concluded that Mr.
Ericson 	failed to 	assert 	actionable claims 	because he 	did not 	identify 	individual
defendants who allegedly violated his rights and his factual allegations were, at best,
conclusory. See ECF No. 14 at 3–4. The Magistrate Judge recommended dismissing the
complaint unless Mr. Ericson amended the complaint within fourteen days of the
Recommended Decision to address the identified deficiencies. See id at 4–5. Mr. Ericson
has not moved to file a second amended complaint, but he filed an objection to the
Recommended Decision, wherein he asserts he purposefully decided not to go into detail
on his claims, in part because Defendants allegedly destroyed any of his documentary
evidence. See ECF No. 20 at 1–2.
The 	Court reviews 	the Recommended Decision 	de 	novo. 	See 	Fed. R. 	Civ.
P. 72(b)(3). For Mr. Ericson to state an actionable claim, the complaint must contain
“sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on
its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly,
550 U.S. 544, 570 (2007)). A claim is plausible on its face when “the plaintiff pleads
factual content that allows the court to draw the reasonable inference that the defendant
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is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). Because Mr.
Ericson is pro se, the Court construes his pleadings liberally. See Erickson v. Pardus, 551
U.S. 89, 94 (2007) (per curiam).
Determining whether a claim is plausible on its face, and thus actionable, is a “two-
step analysis.” Cardigan Mountain Sch. v. N.H. Ins. Co., 787 F.3d 82, 84 (1st Cir. 2015).
First, the Court accepts the factual allegations as true but does not credit any conclusory
legal allegations. See García-Catalán v. United States, 734 F.3d 100, 103 (1st Cir. 2013);
see also Schatz v. Republican State Leadership Comm., 669 F.3d 50, 55 (1st Cir. 2012)
(stating a court may “isolate and ignore statements in the complaint that simply offer legal
labels and conclusions or merely rehash cause-of-action elements”). Second, the Court
determines “whether the factual allegations are sufficient to support ‘the reasonable
inference that the defendant is liable for the misconduct alleged.’” García-Catalán, 734
F.3d at 103 (quoting Haley v. City of Bos., 657 F.3d 39, 46 (1st Cir. 2011)).
Despite the liberal construction of Mr. Ericson’s pleadings, “dismissal of [his] pro
se complaint is appropriate where a plaintiff merely states the formal elements of a claim
without the requisite supporting facts.” Doyle v. Town of Falmouth, No. 19-CV-00229,
2019 WL 5431315, at *2 (D. Me. Oct. 23, 2019) (quotation modified). Mr. Ericson’s
complaint and amended complaint suffer a dearth of such facts. He baldly asserts that
Defendants refused to accommodate his disabilities, lost $700 of his money, discarded
his legal files and personal property, punished him for being deaf and disabled, and
assaulted him. See ECF No. 1 at 3. He does not, however, specify which individuals
allegedly engaged in these activities, when they occurred, or where they happened. See
generally ECF Nos. 1, 11. Without more, Mr. Ericson’s claims “are too disjointed, vague,
and conclusory to permit either the court or the defendant[s] to understand the alleged
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wrongs committed against [them], lacking some or all of the crucial detail of who, what,
when, where, and how.” Byrne v. Maryland, No. 20-CV-00036, 2020 WL 1317731, at *5
(D. Me. Mar. 20, 2020), report and recommendation adopted, 2020 WL 2202441 (D.
Me. May 6, 2020), aff’d, No. 20-1568, 2021 WL 9528311 (1st Cir. Nov. 16, 2021). The
complaint does not offer “enough detail to provide a defendant with ‘fair notice of what
the . . . claim is and the grounds upon which it rests.’” Ocasio-Hernández v. Fortuño-
Burset, 640 F.3d 1, 12 (1st Cir. 2011) (quoting Twombly, 550 U.S. at 555); see also
MacDonald v. Cumberland Cnty. Sheriff, No. 22-CV-00304, 2023 WL 7211253, at *2 (D.
Me. Nov. 2, 2023) (dismissing claim where plaintiff does not “describe the types of threats
she endured or the manner in which the corrections officer assaulted her”).
To the extent Mr. Ericson asserts any constitutional claims under 42 U.S.C. § 1983
or otherwise, he must show that: “(1) the challenged conduct was attributable to a person
acting under color of state law; and (2) the conduct deprived the plaintiff of rights secured
by the Constitution or laws of the United States.” Vélez-Rivera v. Agosto-Alicea, 437 F.3d
145, 151–52 (1st Cir. 2006) (quotation modified). But his pleadings neither name
individual defendants nor direct any factual allegations at an individual defendant. This
renders the complaint insufficient to state constitutional claims against any of the
Defendants. See Dewey v. Univ. of N.H., 694 F.2d 1, 3 (1st Cir. 1982), cert. denied, 461
U.S. 	944 	(1983) 	(a 	valid 	§ 	1983 	claim 	requires 	“minimal 	facts, 	not 	subjective
characterizations, as to who did what to whom and why”); Perry v. Roy, 782 F.3d 73, 78
(1st Cir. 2015) (requiring § 1983 plaintiffs to show “that prison officials possessed a
sufficiently culpable state of mind, namely one of ‘deliberate indifference’ to an inmate’s
health or safety” (quoting Leavitt v. Corr. Med. Servs., 645 F.3d 484, 497 (1st Cir. 2011)).
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For similar reasons, Mr. Ericson’s claims against the identified federal institutional
actors also fail to state a claim. 1 Bivens actions, 2 which govern claims “of a constitutional
violation perpetrated by a federal actor,” Ruiz Rivera v. Riley, 209 F.3d 24, 26 (1st Cir.
2000) (quotation modified), cannot be 	brought “against an agency of the federal
government” or “federal officials sued in their official capacities,” Wen Y. Chiang v.
Skeirik, No. CV 07-10451, 2008 WL 11435593, at *6 (D. Mass. July 3, 2008), aff’d sub
nom. Chiang v. Skeirik, 582 F.3d 238 (1st Cir. 2009). Failure to name the proper
defendants in such an action “mandates the dismissal of the action.” Id. As such, Mr.
Ericson’s claims against the unspecified individual federal Defendants, which are merely
named as the institutions themselves or the federal agents who run them, cannot stand.
Mr. Ericson’s attempts to name the Sheriffs of the Somerset, Cumberland, and
Strafford County Jails also fail. Because Mr. Ericson names the Sheriffs in their official
capacities, the complaint must be construed as a suit against the counties which operate
the jails. See Witham v. Androscoggin Cnty. Sheriff’s Off., No. 12-CV-00078, 2012 WL
5381509, at *4 (D. Me. July 12, 2012), aff’d in part, 2012 WL 5381531 (D. Me. Oct. 31,
2012). 	Under 	§ 1983, 	the 	municipalities 	may 	only 	be 	held liable 	for 	their 	own
unconstitutional actions, not those of their employees. See Monell v. Dep’t of Soc. Servs.,
436 U.S. 658, 691 (1978). In turn, the counties may only be sued if “execution of a
government’s policy or custom . . . inflicts the injury.” Id. at 694.
To assert an actionable claim against the municipalities, Mr. Ericson bears the
burden 	of 	identifying 	a 	municipal 	policy, 	custom, 	or 	practice 	that 	caused 	the
1 The Court assumes for the purposes of this Order that the wardens of the “federal transfer center,” the
“federal medical center,” the “federal trade center,” the Wyatt detention facility, the U.S. Marshals, the
“transportation deputies,” the “air police,” and the “air marshals” are all federal actors.
2 See Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971).
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constitutional deprivation. See Welch v. Ciampa, 542 F.3d 927, 941 (1st Cir. 2008). The
Recommended Decision correctly concludes Mr. Ericson has failed to adduce any facts
sufficient to identify a policy or custom. See ECF No. 14 at 4. Not only does he fail to “plead
that each Government-official defendant, through the official’s own individual actions,
has violated the Constitution,” Iqbal, 556 U.S. at 676, he also fails to establish any
identifiable 	facts 	that 	would 	“support 	a 	plausible 	inference 	that 	[the 	counties’]
decisionmakers maintained or knowingly acquiesced in a widespread policy or custom of
deliberate indifference, nor that any deficiency in County training or supervision rose to
that level,” 	Elisens v. Kennebec Cnty. Corr. Facility, No. 25-CV-00647, 2026 WL
1893613, at *2 (D. Me. July 1, 2026).
Accordingly, Mr. Ericson fails to state a claim on any of the allegations presented
in his complaint and amended complaint. The Court DISMISSES the case in its entirety.
ECF Nos. 1, 11.
MOTION FOR PRELIMINARY INJUNCTION
On September 18, 2025, Mr. Ericson filed a motion for an ex parte temporary
restraining 	order 	(“TRO”) and preliminary 	injunction, 	urging the 	Court to 	order
injunctive relief to address some of his medical complaints during his pretrial detention.
ECF No. 5. On September 24, 2025, the Court denied his motion to the extent it moved
for an ex parte TRO and reserved ruling on the motion for preliminary injunction. ECF
No. 9. As of the date of this Order, Mr. Ericson is no longer in custody, and the underlying
criminal case to which he was subject to pretrial detention has since concluded. See ECF
No. 20 at 1 (providing updated out-of-custody address to Court staff). Because the
conditions challenged in the complaint are no longer applicable to Mr. Ericson, and
because he fails to state a claim on the bases for this suit, his claim for preliminary
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injunctive relief is moot. See D.H.L. Assocs., Inc. v. O’Gorman, 199 F.3d 50, 54 (1st Cir.
1999) (“[W]e are without power to grant injunctive and declaratory relief because the
[challenged] ordinances no longer exist.”). The Court DENIES AS MOOT the motion
for preliminary injunction. ECF No. 5.
CONCLUSION
The Court has reviewed and considered the Magistrate Judge’s Recommended
Decision de novo and in light of the record. The Court concurs with the Magistrate Judge’s
conclusions as set forth in the Recommended Decision and determines that dismissal is
appropriate. Therefore, the Court AFFIRMS and ADOPTS the Recommended Decision.
ECF No. 14. Plaintiff’s complaint is DISMISSED. ECF Nos. 1, 11. Plaintiff’s motion for
preliminary injunction is DENIED AS MOOT. ECF No. 5.
S O ORDERED.
Dated this 27th day of July, 2026.
/s/ Stacey D. Neumann
U NITED S TATES D ISTRICT J UDGE
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