Phillips v. Ingham, County of et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
JUSTIN JARVIS JEROME PHILLIPS,
Plaintiff,
v.
INGHAM COUNTY, et al.,
Defendants.
___________________________________/
Case No. 1:26-cv-27
Hon. Hala Y. Jarbou
ORDER
Plaintiff brings this pro se lawsuit under 42 U.S.C. § 1983, alleging that Defendant Ingham
County and its employees violated his procedural due process rights by maintaining false records
that caused Wayne County to initiate two paternity suits regarding his child. The magistrate judge
issued a report and recommendation (R&R) on January 12, 2026, recommending that the Court
dismiss the case under 28 U.S.C. § 1915(e)(2) for failure to state a claim (ECF No. 7). The
deadline to file objections to the R&R has passed, and no objections have been filed. The Court
has reviewed the R&R and concludes it makes a sound recommendation.
The Court also notes that, in addition to failing to state a claim, Plaintiff has failed to
establish the Court’s subject matter jurisdiction over this case because he has not alleged an injury
sufficient to confer standing. See Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016), as revised
(May 24, 2016) (“[T]he ‘irreducible constitutional minimum’ of standing” includes a requirement
that the plaintiff “suffered an injury in fact.” (quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560
(1992))). Plaintiff alleges that Ingham County falsely recorded the paternity of his child as
“unknown,” which caused Wayne County to initiate two paternity suits regarding that child and
led to “the resulting constitutional violations.” (Compl., ECF No. 1, PageID.4, 6.) But Plaintiff
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provides no details as to what these violations were or what harms the paternity proceedings caused
him. And as the magistrate judge explained, the mere fact that Ingham County maintained an
allegedly inaccurate record about the paternity of Plaintiff’s child is not itself a cognizable harm.
Thus, Plaintiff has not sufficiently pled standing and his complaint must be dismissed for lack of
subject matter jurisdiction.
Accordingly,
IT IS ORDERED that the R&R (ECF No. 7) is APPROVED for the additional reasons
outlined in this Order.
IT IS FURTHER ORDERED that Plaintiff’s claims are DISMISSED for lack of subject
matter jurisdiction.
A judgment will enter in accordance with this Order.
Dated: February 11, 2026 /s/ Hala Y. Jarbou
HALA Y. JARBOU
CHIEF UNITED STATES DISTRICT JUDGE
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