Jeffrey Luffman v. Collinsville Community Unit School District 10

In May 2025, Luffman filed suit under 42 U.S.C. §§ 1983 and 1985, alleging a broad conspiracy between over 30 public officials, government agencies, and law enforcement officers to suppress his protected speech, obstruct his access to public records, conduct unlawful searches and welfare checks, and retaliate against him for what he described without elaboration as his "advocacy efforts." He asserted that this conspiracy violated his rights under the First, Fourth, and Fourteenth Amendments, as well as the Freedom of Information Act, 5 U.S.C. § 552, and—due to his claimed status as a disabled veteran—Title II of the Americans with Disabilities Act, 42 U.S.C. §§ 12131-12165. Because of his purported disability status, he requested counsel to obtain meaningful access to the court.

But his complaint lacked factual support, and it was not clear which claims applied to which defendants. Observing that the complaint failed to include "simple, concise, and direct allegations," the court dismissed the case without prejudice for failure to state a claim and failure to comply with Rules 8 and 10 of the Federal Rules of Civil Procedure. In the same order, the court ordered Luffman to file an amended complaint that complied with Rules 8 and 10, and to show cause why his case should not be dismissed for lack of subject matter jurisdiction.

Luffman then filed an amended complaint which, including its attachments and exhibits, spanned nearly 300 pages and alleged "repeated, ongoing, and coordinated violations of his constitutional, civil, parental, and disability rights." The district court screened the amended complaint, see 28 U.S.C. § 1915(e)(2)(B), and observed that it contained conclusory allegations, was "unnecessarily and confusingly duplicative and lengthy," and the face of the complaint "essentially allege[d] no facts whatsoever." The court noted that Luffman had attempted to "incorporate by reference" over 200 pages of exhibits and attachments in support of his allegations, but that neither the court nor the defendants could be expected to parse these documents to find facts that would support his claims. The court also expressed concern that, because of the confusing way in which Luffman had written his complaint, the defendants would not be able to understand the scope of the allegations against them. The court explained that it was not required to give Luffman another opportunity to amend, and dismissed the complaint with prejudice for failure to provide the defendants adequate notice of the claims against them and failure to state a claim upon which relief could be granted. See F ED. R. CIV. P. 8(a)(2), 12(b)(6).

After the court entered judgment, Luffman filed several motions in which he renewed his request for court-recruited counsel on the basis of his disability, among

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other requests for post-judgment relief. In an order denying these motions, the court observed that Luffman failed to explain how he is disabled within the meaning of the ADA or why recruitment of counsel is a reasonable accommodation. The court also explained that Luffman had failed to demonstrate that he had made any attempts to obtain counsel for his case, as is required of indigent litigants requesting court-recruited counsel under Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007). The court therefore denied Luffman's requests.

Luffman appeals, arguing that the district court abused its discretion when it dismissed his amended complaint for what he contends were merely "technical deficiencies," insisting that his complaint was necessarily lengthy because of the duration and complexity of the alleged conspiracy. He further contends that dismissal with prejudice was improper because his complaint, though lengthy, was not unintelligible as it contained factual allegations supported by the attached exhibits. But the court permissibly determined that Luffman's complaint ran afoul of Rule 8. That rule requires a complaint to contain a "short and plain statement of the claim showing that the pleader is entitled to relief," and Luffman's amended complaint—spanning nearly 300 pages, including attachments, and containing 15 counts against 37 defendants—does not include such a statement. Instead, the complaint contains conclusory allegations that the defendants engaged in unlawful behavior and violated his rights without explaining how they did so or how the defendants' supposed acts relate to one another. In the "factual allegations" section of the complaint, Luffman attempts to "incorporate by reference" the remaining 281 pages of attached appendices and exhibits. Regardless of whether Luffman's allegations are supported by the attachments, attaching exhibits to substantiate a claim does not substitute a "short and plain statement." See F ED. R. CIV. P. 8(a)(2); United States ex rel. Garst v. Lockheed-Martin Corp., 328 F.3d 374, 378-79 (7th Cir. 2003) (concluding that a 155-page complaint followed by 99 attachments was insufficiently straightforward to satisfy Rule 8(a)). The result is unintelligible, as the lack of "basic coherence renders [it] too confusing to determine the facts that constitute the alleged wrongful conduct."

See Stanard v. Nygren, 658 F.3d 792, 798 (7th Cir. 2011). It is inadequate notice to the defendants of Luffman's allegations against them. Dismissal of a complaint on these grounds is "unexceptionable." Garst, 328 F.3d at 378. The court was well within its discretion to dismiss the amended complaint. See Stanard, 658 F.3d at 798. We further agree with the district court that Luffman failed to state a claim upon which relief can be granted. To state a claim, a complaint must "contain allegations that

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plausibly suggest the plaintiff has a right to relief, raising that possibility above a speculative level." Kubiak v. City of Chicago, 810 F.3d 476, 480 (7th Cir. 2016) (internal quotation omitted); see FED. R. CIV. P. 12(b)(6). Luffman's complaint fails to suggest a non-speculative right to relief. Instead, he alleges a wide-ranging conspiracy without demonstrating a logical connection between the defendants, their alleged acts, his claimed injuries, and the relief he seeks. See Wilson v. Price, 624 F.3d 389, 395 (7th Cir. 2010) ("The plaintiffs may not avoid dismissal … simply by attaching bare legal conclusions to narrated facts which fail to outline the basis of their claims." (internal quotation omitted)).

Luffman also argues that the district court erred by dismissing his complaint without giving him another chance to amend. But "[a] district court does not abuse its discretion when it had explained what was wrong with the initial complaint and had already provided one opportunity to amend." Knowlton v. City of Wauwatosa, 119 F.4th 507, 520 (7th Cir. 2024) (internal quotation omitted). In dismissing Luffman's initial complaint without prejudice, the court explained that he failed to include direct and concise allegations. The court then gave Luffman the chance to amend his complaint to cure its defects, instructing him to ensure that the amended complaint met the requirements of Rules 8 and 10 and stated a claim for relief. That Luffman's amended complaint was still defective did not entitle him to a third attempt. Luffman next argues that the court should have recruited counsel to assist him. He suggests that he had a right to counsel under the Sixth Amendment because he eventually faced criminal sanctions in state court for stalking some of the defendants in this suit. But this case is a civil proceeding, so he does not have a Sixth Amendment right to representation. See Eagan v. Dempsey, 987 F.3d 667, 682 (7th Cir. 2021). Luffman also disputes the court's determination that he failed to demonstrate efforts to obtain counsel, as is required before attempting to recruit counsel. Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007). He insists that his efforts to obtain counsel were "frustrated by systemic hostility, judicial sanctions, and barriers tied to his disability." But Luffman does nothing to upset the district court's determination that he failed to make any showing that he had attempted to obtain counsel on his own to begin with. The district court properly denied his request. See Balle v. Kennedy, 73 F.4th 545, 559-60 (7th Cir.

2023).

Finally, Luffman asserts that he was entitled to counsel as a reasonable accommodation under Title II of the Americans with Disabilities Act. But a federal court is not a public entity within the meaning of the Act. See 42 U.S.C. § 12131; Tennessee v.

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Lane, 541 U.S. 509, 517 (2004). Even if it were, Luffman has identified no authority that court-provided counsel is a mandated accommodation under the Act, nor are we aware of any. And in any case, as the district court noted, Luffman never demonstrated that he is disabled within the meaning of the Act, so he cannot show that he is entitled to an accommodation.

We have considered Luffman's remaining arguments, and none has merit.^†

AFFIRMED

† All of Luffman's pending motions are DENIED.

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