ABBOTT v. CIRCUIT COURT 3 OF DELAWARE COUNTY

CourtDistrict Court, S.D. Indiana
DecidedMarch 30, 2021
Docket1:20-cv-02459
StatusUnknown

This text of ABBOTT v. CIRCUIT COURT 3 OF DELAWARE COUNTY (ABBOTT v. CIRCUIT COURT 3 OF DELAWARE COUNTY) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ABBOTT v. CIRCUIT COURT 3 OF DELAWARE COUNTY, (S.D. Ind. 2021).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

MICHELLE ABBOTT, ) ) Plaintiff, ) ) v. ) No. 1:20-cv-02459-JRS-DLP ) CIRCUIT COURT 3 OF DELAWARE ) COUNTY, ) MICHAEL QUIRK, ) CARL BARBER, ) ) Defendants. )

Order on Motions to Dismiss (ECF Nos. 13, 16, 18) In connection with a methamphetamine-related conviction from 2014, Plaintiff Michelle Abbott sued her public defender Michael Quirk, police officer Carl Barber, and the Circuit Court 3 of Delaware County, Indiana (the "Circuit Court"). Abbott, proceeding pro se, brings this action under 42 U.S.C. § 1983, alleging that Defendants' misconduct resulted in the deprivation of her Fourth, Fifth, Sixth, and Fourteenth Amendment rights; she also seems to bring several state law claims, should the com- plaint be construed liberally. Defendants move to dismiss. (See ECF Nos. 13, 16, 18.) Abbott did not respond to the motions to dismiss, and the time for responding has long since passed. See L.R. 7-1(c)(2)(A) ("Responsive briefs are due within 14 days after service of the supporting brief."). Considering Abbott's pro se status, however, the Court will not treat her failure to respond as a forfeiture of her claims because a "pro se plaintiff who has alleged well-pled facts supporting a claim for relief can with- stand dismissal without responding to a motion to dismiss." Curtis v. Bembenek, 48 F.3d 281, 287 (7th Cir. 1995) (citation omitted).

I. Standard of Review A complaint must contain a short and plain statement showing that the pleader is entitled to relief. Conley v. Gibson, 355 U.S. 41, 47 (1957). "To meet this standard, a plaintiff is not required to include 'detailed factual allegations,'" but the factual allegations must "state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if it "pleads factual

content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When considering a motion to dismiss for failure to state a claim, courts "take all the factual allegations in the complaint as true," Iqbal, 556 U.S. at 678, and draw all reasonable inferences in the plaintiff's favor, Roberts v. City of Chicago, 817 F.3d 561, 564 (7th Cir. 2016). Courts, however, need not accept the truth of mere legal conclu- sions. Iqbal, 556 U.S. at 678–79. "[I]f a plaintiff pleads facts that show its suit [is]

barred . . . it may plead itself out of court under a Rule 12(b)(6) analysis." Whirlpool Fin. Corp. v. GN Holdings, Inc., 67 F.3d 605, 608 (7th Cir. 1995) (citation omitted). II. Discussion On October 16, 2014, Abbott pleaded guilty to (1) dealing methamphetamine, Cause No. 18C03-1303-FB-21, and (2) aiding, inducing, or causing dealing in meth- amphetamine, Cause No. 18C03-1403-FB-45. In return, the State dismissed two other charges, Cause Nos. 18C03-1303-FD-43 and 18C03-1312-FD-235. The Court takes judicial notice of the dockets in these cases. Abbott filed the federal complaint here on September 22, 2020. Further facts are discussed below as relevant to each

defendant. A. Michael Quirk As to her public defender, Quirk, Abbot says his "wrongful action was not repre- senting me . . . ." (ECF No. 1 at 6.) Allegedly, Quirk "didn't argue or say anything to help my case"; committed malpractice; never came to jail to speak with Abbott; and "acted with no rules of conduct of [his] position." (Id. at 5.) The most specific conduct

that Abbott points out as poor lawyering is Quirk's advice that she sign a plea agree- ment. (Id. at 7.) Abbott believes Quirk instead should have argued that Abbott could not be charged with abetting dealing when a principal was never convicted—her sis- ter's charge of dealing was ultimately dismissed, Abbott says. (Id. at 7.) Initially, the Court notes that the dismissal of her sister's charge as a principal would not preclude Abbott's conviction for aiding and abetting. See Ind. Code § 35– 41–2–4 ("A person who knowingly or intentionally aids, induces, or causes another

person to commit an offense commits that offense, even if the other person . . . [h]as not been convicted of the offense . . . ."). But the Court need not reach whether mal- practice occurred because the statute of limitations for any malpractice claim expired in 2017 at the latest. "The statute of limitations for a claim of legal malpractice is two years." Saylor v. Reid, 132 N.E.3d 470, 473 (Ind. Ct. App. 2019), transfer denied, 143 N.E.3d 946 (Ind. 2020) (citing Ind. Code § 34–11–2–4). Abbott's convictions oc- curred in October of 2014, so she had to bring a malpractice claim by October of 2016. Even if the Court reads the complaint charitably and finds that she discovered

Quirk's purported legal errors only in November of 2015, when Abbott filed a motion for modification of her sentence that was ultimately granted, she nevertheless had to bring a malpractice claim by November of 2017. Because Abbott only commenced this federal action in September of 2020, her malpractice claims against Quirk are time-barred pursuant to Indiana Code § 34–11–2–4. To the extent Abbott styles her malpractice claim as a § 1983 claim, it also fails.

The statute of limitations for § 1983 claims is the relevant state's statute of limita- tions for personal-injury claims. See, e.g., Wallace v. Kato, 549 U.S. 384, 387 (2007). Here, that is the two-year statute of limitations found in Indiana Code § 34–11–2–4. Abbott's § 1983 claims against Quirk are therefore also time-barred. B. Carl Barber As to Barber, Abbott's non-conclusory allegations are as follows. Barber allegedly falsely charged Abbott of crimes she did not commit. (ECF No. 1 at 5.) Barber has

allegedly stopped Abbott multiple times and stalked Abbott online. (Id.) He purport- edly "harassed" Abbott for months by producing false evidence in support of criminal charges that were eventually dismissed. (Id. at 6.) The officer allegedly "withheld information that [Abbott's] sister said [a meth lab] was all hers." (Id.) And Abbott believes her Fourth Amendment rights were violated when Barber went to her house to deliver a previously seized phone and thereafter obtained consent from Abbott's sister to enter despite the sister not residing or staying there. (Id.) The statute of limitations for bringing a § 1983 claim is two years after the alleged

violation. See Ind. Code § 34–11–2–4; Wallace, 549 U.S. at 387. All of the alleged conduct described above occurred before Abbott's conviction in October of 2014. Be- cause Abbott commenced this federal action in September of 2020, many years after the statute of limitations expired, her Fourth Amendment and due-process claims against Barber are time-barred. To the extent Abbott brings a claim for malicious prosecution—under either

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Randall Curtis v. Brian Bembenek
48 F.3d 281 (Seventh Circuit, 1995)
Steven Hill v. City of Chicago
817 F.3d 561 (Seventh Circuit, 2016)
Julian v. Hanna
732 F.3d 842 (Seventh Circuit, 2013)

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ABBOTT v. CIRCUIT COURT 3 OF DELAWARE COUNTY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abbott-v-circuit-court-3-of-delaware-county-insd-2021.