govinfo:USCOURTS-tnmd-2_26-cv-00027-0

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF TENNESSEE 
NORTHEASTERN DIVISION 
 
KARL WILLIAMS, III, 
 
Plaintiff, 
 
v. 
 
CALEB CATHEY, et al., 
 
Defendants. 
 
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NO. 2:26-cv-00027 
 
 
MEMORANDUM OPINION AND ORDER 
On April 20, 2026, Mississippi resident Karl Williams, III, proceeding pro se, filed a 
Complaint under 42 U.S.C. § 1983 against the Cumberland County Sheriff and three deputies, 
asserting excessive force, racial profiling, false arrest, and other federal and state law claims arising 
from a traffic stop and subsequent events on April 19, 2025. (Doc. No. 1). Plaintiff filed an 
application for leave to proceed in forma pauperis (IFP) (Doc. No. 3) , which he subsequently 
amended. (Doc. No. 7). He also filed an Amended Complaint as of right on April 24, 2026 (Doc. 
No. 6), and a motion for leave to again amend on June 9, 2026. (Doc. No. 8).1 
I. APPLICATION TO PROCEED IFP 
Plaintiff’s amended IFP application sufficiently demonstrates that , with reasonable 
monthly expenses approximating his monthly income and little in the way of liquid or other assets, 
he cannot pay the $405 civil filing fee in advance “without undue hardship.” Foster v. Cuyahoga 
Dep’t of Health and Human Servs., 21 F. App’x 239, 240 (6th Cir. 2001). Accordingly, the 
 
1 As discussed below, Plaintiff’s motion to amend must be denied because it is not supported by a proposed 
amended complaint. The Amended Complaint filed on April 24 is thus Plaintiff’s operative pleading. PageID #: <pageID>
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amended IFP application (Doc. No. 7) is GRANTED. 28 U.S.C. § 1915(a). The original IFP 
application (Doc. No. 3) is DENIED as moot. 
II. INITIAL REVIEW 
A. Legal Standard 
The Court must conduct an initial review and dismiss the Amended Complaint (Doc. No. 
6) if it is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks 
monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); 
see also Ongori v. Hawkins , No. 16- 2781, 2017 WL 6759020, at *1 (6th Cir. Nov. 15, 2017) 
(“[N]on-prisoners proceeding in forma pauperis are still subject to the screening requirements of 
§ 1915(e).”). To avoid dismissal for failure to state a claim, the Amended Complaint must contain 
sufficient factual allegations to render a right to relief “plausible on its face,” Small v. Brock, 963 
F.3d 539, 540 (6th Cir. 2020) (quoting Ashcroft v. Iqbal , 556 U.S. 662, 678 (2009)), such that it 
would survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). Hill v. Lappin, 
630 F.3d 468, 470–71 (6th Cir. 2010). Section 1983 provides a right to relief if the Amended 
Complaint plausibly alleges (1) a deprivation of a constitutional or other federal right, and (2) that 
the deprivation was caused by a “state actor.” Carl v. Muskegon Cnty., 763 F.3d 592, 595 (6th Cir. 
2014). 
At this stage, “the Court assumes the truth of ‘well- pleaded factual allegations’ and 
‘reasonable inference[s]’ therefrom,” Nat’l Rifle Ass’n of Am. v. Vullo, 602 U.S. 175, 181 (2024) 
(quoting Iqbal, 556 U.S. at 678–79), but is “not required to accept legal conclusions or unwarranted 
factual inferences as true.” Inner City Contracting, LLC v. Charter Twp. of Northville, Michigan, 
87 F.4th 743, 749 (6th Cir. 2023) (citation omitted). The Court must also afford the pro se pleading PageID #: <pageID>
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a liberal construction, Erickson v. Pardus , 551 U.S. 89, 94 (2007), while viewing it in the light 
most favorable to Plaintiff. Inner City, supra. 
B. Factual Allegations 
The Amended Complaint alleges that, on April 19, 2025, Plaintiff was pulled over while 
driving through Crossville, Tennessee on Interstate 40. (Doc. No. 6 at 4, 9). Defendant Caleb 
Cathey purportedly stopped Plaintiff for an alleged traffic violation, though Plaintiff states that no 
traffic violation was committed and no traffic citation was issued. (Id. at 9). Plaintiff exhibited no 
signs of intoxication. (Id.). Nonetheless, Cathey was hostile. Plaintiff informed Cathey during the 
stop that Plaintiff suffered from depression and was experiencing significant anxiety and panic. 
(Id.). When Cathey called additional officers to the scene, Plaintiff became frightened and “briefly 
ran into the roadway out of fear and emotional distress, not with the intent to flee or evade arrest.” 
(Id.). Plaintiff “was detained while a K -9 unit was deployed and officers conducted a search of 
Plaintiff’s vehicle, but no contraband or illegal items were found.” (Id.). Cathey arrested Plaintiff 
on suspicion of driving under the influence (DUI). (Id.). Cathey used physical force to restrain 
Plaintiff, causing a contusion “through excessively tight handcuffing” and resulting pain in 
Plaintiff’s right wrist, for which Plaintiff was later prescribed ibuprofen and physical therapy. (Id. 
at 5, 9, 10). The other officers at the scene were Defendants Zach Early and Blake Richardson, and 
both are alleged to have “assist[ed] with the detention of Plaintiff.” (Id. at 8). Plaintiff alleges that 
neither Cathey, Early, nor Richardson had probable cause “to believe Plaintiff had committed any 
crime.” (Id. at 9). After Plaintiff was transported to a hospital for a mental health evaluation (id.) 
and a blood draw (id. at 10), Cathey obtained a warrant for his arrest. ( Id. at 9). Cathey’s official 
report falsely accused Plaintiff of “drug -related conduct.” ( Id. at 12). The DUI charge against 
Plaintiff was subsequently dismissed. (Id. at 9). PageID #: <pageID>
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C. Analysis 
The Amended Complaint asserts seven federal claims based on alleged violations of 
Plaintiff’s rights under the U.S. Constitution, as well as five pendent state law claims . Officers 
Cathey, Early, and Richardson are sued in their individual and official capacities, while Sheriff 
Cox is sued in his official capacity only. (Doc. No. 6 at 2–3). The seven federal claims asserted 
are: (1) racial profiling in violation of the Fourteenth Amendment’s Equal Protection Clause 
against Cathey, Early, and Richardson; (2) illegal search and seizure under the Fourth Amendment 
against Cathey, Early, and Richardson; (3) excessive force under the Fourth Amendment against 
Cathey; (4) false arrest and unlawful detention against Cathey; (5) failure to intervene against Early 
and Richardson; (6) violation of bodily integrity against Cathey; and (7) deliberate indifference 
with respect to municipal policies, customs, train ing, and supervision against Sheriff Cox. (Id. at 
10–11). 
These claims appear to have been timely filed,2 and the Court cannot say at this point that 
any of them are implausibly pled against Cathey, Early, and Richardson in their individual 
capacity. Further factual development is required as to these claims and Plaintiff’s state law 
claims,3 particularly insofar as they turn on determinations of reasonableness and probable cause. 
See Jones v. City of Elyria, Ohio, 947 F.3d 905, 917 (6th Cir. 2020) (“Ascertaining whether force 
was excessive in any given case … is a fact-intensive inquiry[.]”); Bracken v. Manor Twp., 665 F. 
 
2 Plaintiff claims that he was injured on April 19, 2025. Under the statute of limitations applicable to Section 
1983 actions, he had one year to file suit, and that year ended “on the same calendar date the following 
year.” Merriweather v. City of Memphis , 107 F.3d 396, 398 (6th Cir. 1997) . However, because April 19, 
2026 was a Sunday, the last day of the limitations period was Monday, April 20, 2026, see id. (applying 
Fed. R. Civ. P. 6(a))––the day the original Complaint was filed. 
 
3 The state law claims arise from the same facts recited above and include (1) intentional infliction of 
emotional distress against Cathey, Early, and Richardson; and (2) battery, (3) assault, (4) defamation, and 
(5) malicious prosecution against Cathey. (Doc. No. 6 at 11–12). PageID #: <pageID>
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Supp. 3d 675, 691 (W.D. Pa. 2023), aff’d sub nom. Bracken v. Twp. of Manor, No. 23-1763, 2024 
WL 4210535 (3d Cir. Sept. 17, 2024) (“In general, the question of probable cause in a section 
1983 damages suit is a question of fact for the jury, unless there is only one reasonable 
determination possible. … Courts employ an objective and fact intensive test to determine whether 
probable cause existed at the time of the arrest.”) (citation and internal quotation marks omitted); 
cf. Williams v. City of Grand Rapid s, 672 F. Supp. 3d 395, 407 (W.D. Mich. 2023) (analyzing 
similar claims at the summary judgment stage). Plaintiff’s federal claims against Cathey, Early, 
and Richardson in their individual capacity will proceed for further development, as will his 
pendent state law claims. 
The claims against the Cumberland County Sheriff and his deputies in their official 
capacity, however, are effectively claims against Cumberland County. See Alkire v. Irving, 330 
F.3d 802, 810 (6th Cir. 2003) (holding that “individuals sued in their official capacities stand in 
the shoes of the entity they represent”). As such, they require allegations supporting a plausible 
claim that Plaintiff’s “ constitutional rights were violated and that a policy or custom of 
[Cumberland County] was the ‘moving force’ behind the deprivation of Plaintiff’s rights.” Okolo 
v. Metro. Gov’t of Nashville, 892 F. Supp. 2d 931, 941 (M.D. Tenn. 2012) (citing Miller v. Sanilac 
County, 606 F.3d 240, 254–55 (6th Cir. 2010)) . “That policy or custom must be specific; if a 
complaint pleads facts that are ‘merely consistent with’ liability, it ‘stops short of the line between 
possibility and plausibility of relief. ’” Patterson v. City of Clarksville , No. 3:23-cv-00682, 2025 
WL 3048999, at *5 (M.D. Tenn. Oct. 31, 2025) (quoting Hutchison v. Metro. Gov’t of Nashville 
& Davidson Cnty., 685 F. Supp. 2d 747, 751 (M.D. Tenn. 2010)). 
Here, the Amended Complaint alleges that Sheriff Cox “had responsibility over the 
operations of the Sheriff’s Office, including policies, training, supervision, discipline, and law - PageID #: <pageID>
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enforcement practices of deputies.” (Doc. No. 6 at 8). It further alleges that Cox, “in his official 
capacity as Sheriff of Cumberland County and final policymaker for the Cumberland County 
Sheriff’s Office, maintained policies, customs, or practices and failed to adequately train and 
supervise deputies regarding lawful traffic stops, probable cause determinations, and the use of 
force”––though “[t]he precise details of these policies, customs, training practices, and supervision 
are within the control of Defendants [so must] be revealed through discovery.” (Id. at 11). 
If in discovery Plaintiff ascertains particular policies and training practices that he believes 
produced the injuries he has alleged, or a total lack of policies or training practices that ought to 
have been in place, he may seek to amend in order to include a municipal liability claim at that 
point. See Ouza v. City of Dearborn Heights, Michigan, 969 F.3d 265, 286–89 (6th Cir. 2020) 
(“The failure to provide any training on probable cause determinations or use of force (including 
handcuffing technique) is constitutionally inadequate.”). At this point, however , the Amended 
Complaint’s municipal liability claim is made up of only “formulaic recitations of the elements of 
a cause of action and supporting conclusory statements” which are not entitled to the presumption 
of truth, Okolo, 892 F. Supp. 2d at 943, and which are not sufficient to state a claim against the 
County that would plausibly, and not merely possibly, entitle Plaintiff to relief. See Birgs v. City 
of Memphis, 686 F. Supp. 2d 776, 780–81 (W.D. Tenn. 2010) (reviewing similar allegations and 
finding that, “[s]tripped of legal language, the Complaint contains no facts that could plausibly 
lead one to believe” that the city is liable for its officers’ use of excessive force). Accordingly, 
Sheriff Cox will be dismissed from this action, as will the official capacity claims against the 
remaining Defendants. PageID #: <pageID>
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III. CONCLUSION 
As explained above, Plaintiff’s individual capacity claims against Defendants Cathey, 
Early, and Richardson are sufficiently pled to survive initial review. However, the Court’s 
determination that the Complaint states colorable claims for purposes of this initial screening does 
not preclude the Court from dismissing any claim at any time for the reasons set forth in 28 U.S.C. 
§ 1915(e)(2), nor does it preclude any Defendant from filing a motion to dismiss any claim under 
Federal Rule of Civil Procedure 12. 
Defendant Casey Cox is DISMISSED from this action. The official- capacity claims 
against the remaining Defendants are also DISMISSED. 
Plaintiff’s Motion for Leave to File Third Amended Complaint (Doc. No. 8) refers to “the 
attached Proposed Third Amended Complaint” (id. at 1, 2), but no proposed pleading is attached 
to the Motion. The Motion therefore fails to comply with Local Rule 15.01, which requires that 
“the signed proposed amended pleading” be attached “as an appended exhibit.” M.D. Tenn. L.R. 
15.01(a)(1). Accordingly, the Motion for Leave to File Third Amended Complaint (Doc. No. 8) is 
DENIED WITHOUT PREJUDICE. 
The Clerk is DIRECTED to send Plaintiff a service packet (a blank summons (AO 440) 
and USM 285 form) for each of the three remaining Defendants . Plaintiff MUST complete the 
service packets and return them to the Clerk’s Office within 30 DAYS of the entry of this Order. 
Failure to do so may result in the dismissal of this case. Upon return of the properly completed 
service packets, the Clerk is DIRECTED to issue summons to the U.S. Marshals Service for 
service on the defendants. Fed. R. Civ. P. 4(b) and (c)(3). 
This action is REFERRED to the Magistrate Judge to oversee service of process, to enter 
a scheduling order for the management of the case, to dispose or recommend disposition of any PageID #: <pageID>
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pretrial motions under 28 U.S.C. §§ 636(b)(1)(A) and (B), and to conduct further proceedings, if 
necessary, under Rule 72(b) of the Federal Rules of Civil Procedure and the Local Rules of Court. 
Plaintiff is cautioned that he must keep the Court informed of his current address at all 
times, or risk dismissal of this action for failure to prosecute. See Fed. R. Civ. P. 41(b); M.D. Tenn. 
L.R. 41.01(b). Additional resources for pro se litigants, including forms, handbooks, and 
information sheets, are available on the court’s website. See 
https://www.tnmd.uscourts.gov/representing-yourself-federal-court. 
IT IS SO ORDERED. 
 
____________________________________ 
WAVERLY D. CRENSHAW, JR. 
UNITED STATES DISTRICT JUDGE PageID #: <pageID>

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