Agee v. Reno Police Department

CourtDistrict Court, D. Nevada
DecidedFebruary 18, 2025
Docket3:24-cv-00306
StatusUnknown

This text of Agee v. Reno Police Department (Agee v. Reno Police Department) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Agee v. Reno Police Department, (D. Nev. 2025).

Opinion

2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 * * * 6 KEENEN R. AGEE, Case No. 3:24-cv-00306-MMD-CSD 7 Plaintiff, ORDER v. 8 RENO POLICE DEPARTMENT, et al., 9 Defendants. 10 11 I. SUMMARY 12 Pro se Plaintiff Keenen R. Agee brings this action under 42 U.S.C. § 1983, 13 alleging that numerous City of Reno Defendants (“City Defendants”1) and Washoe 14 County Defendants (“County Defendants”2) violated his civil rights when he was 15 arrested on two occasions in 2023 and prosecuted for domestic battery, among other 16 offenses, in Nevada state court.3 (ECF No. 10 (“Amended Complaint”).) All state 17 criminal charges filed against Agee were ultimately dismissed before reaching trial. 18 Now before the Court are County and City Defendants’ respective motions to 19 dismiss. (ECF Nos. 14 (“County Defendants’ Motion”4); 16 (“City Defendants’ Motion”5).) 20 21 22 1City Defendants are the City of Reno, the Reno Police Department (“RPD”), Police Chief Kathryn Nance, Mayor Hillary Schieve, Director of Finance Vicki Van 23 Buren, and RPD Officers Christopher Rose, Derek Jones, and Dylan Staples. (ECF No. 10.) 24 2County Defendants are Washoe County District Attorney (“D.A.”) Christopher 25 Hicks; Deputy D.A. Stephan Hollandsworth; County Public Defender (“P.D.”) Evelyn Grosenick; and Deputy P.D. Scott Fahrendorf. (ECF No. 10.) 26 3Because Plaintiff is not incarcerated, screening of the Amended Complaint is not 27 required under 28 U.S.C. § 1915A. 28 4Plaintiff responded to County Defendants’ Motion (ECF No. 26) and County Defendants replied (ECF No. 33). 2 against the named Reno officials and entities, but gives Plaintiff leave to amend his 3 claims against Police Chief Nance and the City of Reno. The Court also grants County 4 Defendants’ Motion as to all claims against the named Washoe County prosecutors and 5 public defenders, but dismisses some claims against D.A. Hicks and Deputy D.A. 6 Stephan Hollandsworth without prejudice. The Court further grants County Defendants’ 7 motion to strike Plaintiff’s fugitive supplemental filing (ECF No. 46 (“Motion to Strike”)). 8 Finally, given that the Court will independently permit Plaintiff to amend, the Court 9 denies as moot Plaintiff’s motion to file a second amended complaint (ECF No. 53 10 (“Motion to Amend”)6) adding allegations related to an additional arrest. However, if 11 Plaintiff wishes to assert claims related to the newly-identified arrest in his third 12 amended complaint, he may do so only within the limited bounds of this order, and he 13 may not assert a claim arising under the Fifth Amendment. 14 II. BACKGROUND7 15 Agee initiated this lawsuit after he was arrested by RPD Officers in Reno, 16 Nevada, on two occasions in 2023 roughly four months apart. (ECF Nos. 1, 10.) 17 Following each of these arrests, Plaintiff faced state-court criminal charges, including 18 several charges for domestic battery.8 (ECF Nos. 1-3, 10, 14.) The Washoe County 19 District Attorney’s Office prosecuted Agee, but all charges were ultimately dropped. (Id.) 20 5RPD Officers Rose, Jones, and Staples answered Plaintiff’s Amended 21 Complaint (ECF No. 15) and do not move for dismissal with the other City Defendants. Plaintiff responded to City Defendants’ Motion (ECF No. 24) and City Defendants 22 replied (ECF No. 31).

23 6City Defendants responded to the Motion to Amend (ECF No. 61) and County Defendants joined that response (ECF No. 62). 24 7The following facts are adapted from the Amended Complaint (ECF No. 10) 25 unless otherwise noted.

26 8The Court takes judicial notice of Reno Justice Court filings in Case Nos. RCR202-123337 and RCR2023-122008, where these filings are relevant to the pending 27 motions and where notice is appropriate. (ECF No. 1-3). See Tellabs, Inc. v. Makor Issues & Rts., Ltd., 551 U.S. 308, 322 (2007) (noting that when ruling on a motion to 28 dismiss, a court may consider, inter alia, “documents incorporated into the complaint by 2 operative Amended Complaint (ECF No. 10) shortly thereafter, making largely the same 3 substantive allegations but adding defendants. Plaintiff sues various City Defendants— 4 naming the individual RPD officers involved in his arrests, Mayor Hillary Schieve, 5 Finance Director Vicki Van Buren, Police Chief Nance, RPD, and the City of Reno itself. 6 (Id.) He also sues multiple Washoe County Defendants connected to the District 7 Attorney’s Office and Public Defender’s Office—naming the County’s elected D.A. 8 Christopher Hicks, Deputy D.A. Hollandsworth, appointed P.D. Evelyn Grosenick, and 9 Deputy P.D. Scott Fahrendorf. (Id.) 10 Plaintiff first alleges that he was “wrongfully arrested and threatened bodily harm” 11 on February 2, 2023, in relation to an unidentified “alleged crime” which occurred 12 several weeks earlier. (Id. at 5.) Agee was sitting in his parked car when RPD Officer 13 Derek Jones approached from behind and, upon recognizing Plaintiff, told him he was 14 under arrest for pending charges, while demanding he get out of his car. (Id.) Officer 15 Jones “refused to tell [Agee] why [he] was under arrest,” stating he would only tell Agee 16 the charges against him after he exited the car, and further threatening that “he w[ould] 17 bust the windows out and drag [Agee] out” if Plaintiff refused to comply. (Id.) Plaintiff 18 ultimately got out of his car “under fear and coerced terms,” as he was afraid he would 19 otherwise be physically harmed or would suffer property damage. (Id.) 20 Plaintiff was arrested again on May 28, 2023. (Id.) On that day, while returning 21 home from a hair appointment, he was stopped by RPD Officer Dylon Staples, who was 22 driving an unmarked SUV. (Id.) Officer Staples put Agee in handcuffs for attempting to 23 record the encounter. (Id.) RPD Officer Christopher Rose arrived at the scene in

24 reference, and matters of which a court may take judicial notice”); U.S. ex rel. Robinson Rancheria Citizens Council v. Borneo, Inc., 971 F.2d 244, 248 (9th Cir. 1992) (providing 25 that a Court may take judicial notice of proceedings in other courts which are directly related to matters at issue). Plaintiff does not specify the criminal brought against him in 26 his allegations in the Amended Complaint, but court records attached to his original complaint indicate that he was arrested in February 2023 for domestic battery and first 27 degree home invasion, and in May 2023 for home invasion constituting domestic battery, second degree burglary, preventing 911 call, child endangerment, and first 28 degree domestic battery. (ECF No. 1-3.) 2 Although Agee followed all commands, Officer Staples stopped him and slammed him 3 to the ground with enough force that he could have been “crippled or killed.” (Id.) 4 Because Plaintiff was in handcuffs with his arms locked behind his back, he could not 5 catch himself to lessen the impact of the fall. (Id.) On the ground, still handcuffed, Agee 6 was “dragged.” (Id. at 5-6.) He suffered third degree burns on his shoulders, which 7 remained visible long after the incident, as well as a wrist fracture and wrist cuts. (Id.) 8 Plaintiff informed the officers that he needed medical help, but the request was denied, 9 and he was put in an “unnecessary wrap” and sent to Washoe County Detention Center 10 with no treatment for his injuries. (Id.) 11 After these arrests, the Washoe County District Attorney’s Office pursued 12 charges against Agee.

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Agee v. Reno Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/agee-v-reno-police-department-nvd-2025.