Aguilar Mendez v. St. Johns County

CourtDistrict Court, M.D. Florida
DecidedMay 14, 2025
Docket3:24-cv-00195
StatusUnknown

This text of Aguilar Mendez v. St. Johns County (Aguilar Mendez v. St. Johns County) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aguilar Mendez v. St. Johns County, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA

) VIRGILIO AGUILAR MENDEZ, ) ) Plaintiff, ) ) v. ) CIVIL ACTION ) NO. 3:24-00195-WGY-PDB ST. JOHNS COUNTY, a political ) subdivision of the State of ) Florida, MICHAEL KUNOVICH, through ) his personal representative of his ) estate, in his official and ) individual capacity as a St. Johns ) County police officer, and ROBERT ) A. HARDWICK, in his official ) capacity as Sheriff of St. Johns ) County and his individual capacity ) as a St. Johns County police ) officer, GAVIN HIGGINS, in his ) individual capacity as a St. Johns ) County police officer, and GEORGE ) MONTGOMERY, in his individual ) capacity as a St. Johns County ) police officer, ) ) ) Defendants. ) )

YOUNG, D.J.1 May 14, 2025

ORDER

Virgilio Aguilar Mendez (“Aguilar Mendez”) brought this suit against St. Johns County, Michael Kunovich (“Kunovich”) through the representative of his estate and in his official and individual capacity as a St. Johns County police officer, Robert

1 Of the District of Massachusetts, sitting by designation. A. Hardwick (“Hardwick”) in his official capacity as Sheriff of St. Johns County and his individual capacity, and Gavin Higgins (“Higgins”) and George Montgomery (“Montgomery”) in their

individual capacities as St. Johns County police officers (collectively, “the Defendants”). See Second Am. Compl. (“SAC”), ECF No. 44. Aguilar Mendez alleges that Kunovich unconstitutionally searched and seized him in violation of the Fourth Amendment; that Higgins and Montgomery, together with Kunovich, falsely arrested and battered him under Florida law; that St. Johns County and Hardwick in his official capacity violated the Equal Protection Clause, established unconstitutional policies or customs that caused him injury, and failed to train Kunovich and others, also causing him harm; that Hardwick in his official capacity defamed him in connection with a constitutional violation, inflicting a “stigma plus” injury;

and that Hardwick in his individual capacity defamed him, abused legal process, and intentionally inflicted emotional distress on him, the last of which Kunovich did as well. Id. ¶¶ 113-239. The Defendants moved to dismiss all counts against them. Def. Def. St. Johns County’s Mot. Dismiss Pl.’s Second Am. Compl. (“Def. St. Johns County Mem.”), ECF No. 48; Defs. Higgins & Montgomery’s Mot. Dismiss Pl.’s Second Am. Compl. (“Defs. Higgins & Montgomery’s Mem.”), ECF No. 49; Def. Kunovich’s Mot. Dismiss Pl.’s Second Am. Compl. (“Def. Kunovich’s Mem.”), ECF No. 50; Def. Sheriff Hardwick’s Mot. Dismiss Pl.’s Second Am. Compl. (“Def. Hardwick’s Mem.”), ECF No. 51. Aguilar Mendez opposed these motions. Mem. Law Opp’n Mot. Dismiss Def.

Kunovich (“Pl.’s Opp’n Kunovich”), ECF No. 55; Mem. Law Opp’n Mot. Dismiss Defs. Higgins & Montgomery (“Pl.’s Opp’n Higgins & Montgomery”), ECF No. 56; Mem. Law Opp’n Mot. Dismiss Def. Hardwick (“Pl.’s Opp’n Hardwick”), ECF No. 57; Mem. Law Opp’n Mot. Dismiss Def. St. Johns County (“Pl.’s Opp’n St. Johns”), ECF No. 58. At a hearing held on April 30, 2025, after hearing argument, this Court took the matter under advisement. Minute Entry, ECF No. 66. The Defendants’ motions to dismiss are hereby DENIED in part as to all counts against Kunovich and against Higgins and Montgomery, and ALLOWED in part as to all counts against St. Johns County and Hardwick.

First, Kunovich’s motion to dismiss is denied as to all counts against him. Aguilar Mendez adequately alleges that Kunovich stopped and seized him without reasonable suspicion, grabbing his arm and ordering him not to walk away based only on his presence in a (possibly) high-crime area, SAC ¶¶ 41-57, 150, 176-77, which is unconstitutional under clearly established law, Brown v. Texas, 443 U.S. 47, 51-52 (1979) (“The fact that [the suspect] was in a neighborhood frequented by drug users, standing alone, is not a basis for concluding that [the suspect] himself was engaged in criminal conduct.”). Kunovich’s argument that Aguilar Mendez was in fact fleeing, Def. Kunovich’s Mem. 11-12, presents a fact issue not proper for this Court to resolve at this stage.2 Aguilar Mendez also adequately alleges

that Kunovich knowingly escalated this seizure into a false arrest for a malicious purpose, that is, to cover up the initial unconstitutional stop and with disregard for the arrest’s unconstitutionality, Compl. ¶ 135, overcoming the statutory immunity bar on tort actions based on non-malicious acts done in the course of an officer’s duty, see Butler v. Gualtieri, 41 F. 4th 1329, 1336-38 (11th Cir. 2022) (describing the fact- intensive nature of the question whether an officer acted with malice, bad faith, or willful disregard of human rights, such that the officer may be held liable for actions done in the course of duty under Fla. Stat. § 768.28(9)(a)); see also

2 Aguilar Mendez’s complaint references Kunovich’s Body-Worn Camera video several times, see Compl. ¶¶ 38, 49, 57, 95, 97, 125, 233; Sgt. Kunovich’s Body-Warn Camera Footage, ECF No. 50- 1, but Aguilar Mendez disputes the authenticity of the video, Pl.’s Opp’n Kunovich 3-5. Although Aguilar Mendez did not squarely raise the authenticity issue at the April 30 hearing, nor apparently when conferring with opposing counsel, Def. Kunovich’s Mem. 4, this Court therefore does not consider the video here, see Baker v. City of Madison, Ala., 67 F. 4th 1268, 1276 (11th Cir. 2023) (allowing for incorporation-by-reference of documents attached to motion to dismiss where “documents’ contents are undisputed” (emphasis added)) -- while noting that, in any case, factual allegations are accepted at the motion to dismiss stage “where no obviously contradictory video evidence is available,” id. at 1277-78, which presents a high bar where the allegations center on a protracted scuffle. Robbins v. City of Miami Beach, 613 So.2d 580, 581 (Fla. 3d DCA 1993) (permitting false arrest claim to go forward based on pretextual arrest theory, and describing right to non-violently

resist unlawful arrest); that he used excessive force in effecting the arrest, committing a state law battery, also with malice; and that he intentionally and maliciously inflicted emotional distress on Aguilar Mendez by stopping him without suspicion and escalating the stop into a knowingly false arrest which, after a lengthy struggle and the use of excessive force from multiple officers, culminated in a long imprisonment, see Corbin v. Prummell, 655 F. Supp. 3d 1143, 1165 (M.D. Fla. 2023) (noting that, although the outrageousness standard for intentional infliction of emotional distress claims is “extremely high” under Florida law, police officers are held to a higher standard due to their actual or apparent authority and

the potential for abuse of their position (citation omitted)). Second, Higgins and Montgomery’s motion to dismiss is also denied. Aguilar Mendez alleges that he began passively resisting arrest at some point after Kunovich seized him, Compl. ¶¶ 63-64, but, drawing all inferences in his favor as this Court must at this stage, Aguilar Mendez plausibly alleges that Higgins and Montgomery knew there was no reasonable suspicion for the initial stop or probable cause for the arrest, id. ¶ 136, and thus that they too maliciously used excessive force to effect an unlawful arrest, see Gomez v. Lozano, No. 09-22988- CIV, 2010 WL 11505113, at *6 (S.D. Fla. Dec. 30, 2010) (acknowledging conclusory nature of plaintiff’s malice

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Bluebook (online)
Aguilar Mendez v. St. Johns County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aguilar-mendez-v-st-johns-county-flmd-2025.