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Federal Courts Can't Dismiss Prisoners' Civil Rights Actions Simply Because They're Inartfully Pleaded

Walter Gordon, a South Carolina state prisoner, sued prison officials in federal district court under 42 U.S.C. § 1983 after he was assaulted and raped by other prisoners. Stephen Young, a Maryland state prisoner, filed his federal suit to recover property stolen by prison guards during a search of his cell. Neither complaint was well written. Gordon was allowed to amend his complaint, to little avail, and Young wasn't allowed to amend his. The district courts dismissed on summary judgment, and the cases were consolidated on appeal.

On appeal, the U.S. Court of Appeals for the 4th Circuit found that, although the prisoners’ claims weren't well pleaded, there existed disputed facts on which the prisoners might prevail. Since the same precluded dismissal on summary judgment, both cases were remanded to the district courts for further proceedings. See: Gordon v. Leeke, 574 F.2d 1147 (4th Cir. 1978).

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Related legal case

Gordon v. Leeke