Alemayehu v. Seattle Police Department

CourtDistrict Court, W.D. Washington
DecidedOctober 10, 2024
Docket2:24-cv-01378
StatusUnknown

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

Bluebook
Alemayehu v. Seattle Police Department, (W.D. Wash. 2024).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 AZEB ALEMAYEHU, CASE NO. 2:24-cv-01378-JNW 8 Plaintiff, ORDER 9 v. 10 SEATTLE POLICE DEPARTMENT, 11 Defendant. 12 13 14 1. INTRODUCTION 15 Pro se Plaintiff Azeb Alemayehu pursues this action against Defendant 16 Seattle Police Department (SPD) in forma pauperis (IFP). Dkt. No. 5. After 17 reviewing the operative complaint, Dkt. No. 6, under 28 U.S.C. § 1915(e)(2)(B), the 18 Court finds that Alemayehu fails to state a claim on which relief may be granted. 19 Rather than dismissing her case outright, however, the Court grants Alemayehu 20 leave to amend her complaint within 30 days of this Order to address the problems 21 identified below to save her case from dismissal. 22 23 1 2. BACKGROUND 2 On August 30, 2024, pro se Plaintiff Azeb Alemayehu filed a Motion for Leave

3 to Proceed in Forma Pauperis (IFP) and a Proposed Complaint. Dkt. No. 1. While 4 the legal claims in the Proposed Complaint were unclear, the Proposed Complaint 5 did provide a rough picture of the factual allegations underlying those claims. In the 6 section entitled Statement of Claim, Alemayehu wrote: “Civil Right Violation, SPD 7 Entered into my Apt, my daughter opened the door.” Dkt. No. 1-1 at 5. Then, in a 8 ten-page handwritten attachment, Alemayehu explained in greater detail:

9 …I was at the restroom, completely naked and was ready to take a Shower… there wasn’t any towels at the restroom… when SPD, Seattle 10 Police Department Entered in my house Unlawfully, violates my Civil Right and Put my Daughter, and me in the most… traumatic Position 11 that left a Scar… The day that SPD Showed up early Morning… I was at the restroom completely Naked. SPD got in my Apartment, Stand by 12 the Hallways B/n my bed room and the restroom. I asked, requested if they perhaps step out of the door so I can put some clothes on, before I 13 speak to them, or per haps if they can give me some clothes so (illegible)… be able to wear (illegible)… Before I talk to them and answer 14 their Questions to why they are In my Apt to begin with, but they refused to do so, even though I screamed so many times . . . . Please step 15 out side from the hallways they were standing and wait for me, My daughter saw me completely naked in front of Polices, I was Forced to 16 leave the restroom and Stand up in Front of Public SPD Cameras Viewing me From every Police Stations in Washington States. She was 17 broken, Ashamed, Sad, traumatized For long time…

18 Id. at 7-16. 19 On September 3, 2024, Alemayehu filed a Proposed Amended Complaint. 20 Dkt. No. 4. The Proposed Amended Complaint offers far less factual detail than the 21 original Proposed Complaint. It offers no “Statement of Claim” and provides almost 22 no factual allegations. In lieu of the ten-page attachment from the initial Proposed 23 Complaint (quoted above), it contains only one handwritten page, reading: “I was at 1 the rest room, I didn’t know SPD was standing by the door on the hall way waiting 2 for me, there was (illegible)… any towels at the restroom, I asked, Pleaded, begged

3 them if they actually can hand me to.” Dkt. No. 4-1 at 10. It also contains several 4 attachments, such as a Federal Bar Association brochure, none of which appear 5 relevant. See generally Dkt. No. 4-1. 6 On September 5, 2024, the Honorable Judge S. Kate Vaughn granted 7 Alemayehu’s Application for Leave to Proceed In Forma Pauperis. Dkt. No. 5. As a 8 result, the Amended Complaint was filed on September 5, 2024, formally initiating

9 this action. Dkt. No. 6. 10 On September 12, 2024, Alemayehu once again submitted another Proposed 11 Amended Complaint. Dkt. No. 7. This one contains more detail than the preceding 12 one. Seeking between $500,000,000 and $1,000,000,000 in monetary damages, it 13 alleges that “SPD squizes the handcuffs on my wrists until my blood flooded on the 14 ground and dripped all over the ground.” Id. at 4, 10. It further alleges: 15 “Seattle Police department destpached polices in my resident at [address] made my 12 years old daughter open the front door, I was in 16 the restroom completely naked, there wasn’t any towels, I told them that screaming out loud and asks them to step out or if they can hand me 17 some kind of cloths but they forced me to leave the restroom completely naked on camera from all over the police stations.” 18 Id. 19 However, because this new amended complaint contained the name of a 20 minor child, the Court placed it under seal as required by Federal Rule of Civil 21 Procedure 5.2(a) and Local Rule of Civil Procedure 5.2 and instructed Alemayehu to 22 23 1 file a redacted version without that information. See Dkt. To date, Alemayehu has 2 not filed a redacted version of the proposed amended complaint.

3 3. DISCUSSION 4 When a plaintiff proceeds in forma pauperis, the court must dismiss the 5 action if the court determines the action is frivolous or malicious, fails to state a 6 claim on which relief may be granted, or seeks monetary relief against a defendant 7 who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). When reviewing 8 complaints under § 1915(e)(2)(B), courts necessarily consider only the operative

9 complaint. Here, the operative complaint is the amended complaint submitted on 10 September 5, 2024—not the original proposed complaint submitted on August 30, 11 2024, nor the later proposed amended complaint submitted on September 12, 2024. 12 See Valadez-Lopez v. Chertoff, 656 F.3d 851, 857 (9th Cir. 2011) (holding that an 13 amended complaint supersedes the original and renders the original of no legal 14 effect). Because this Court’s § 1915(e)(2)(B) review is limited to the operative 15 complaint, the Court cannot consider the factual allegations from the initial

16 proposed complaint or later amended complaint. 17 Under the Federal Rules of Civil Procedure, “[p]leadings must be construed 18 so as to do justice.” Fed. R. Civ. P. 8(e). Thus, a “document filed pro se is to be 19 liberally construed and a pro se complaint, however inartfully pleaded, must be held 20 to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. 21 Pardus, 551 U.S. 89, 94 (2007) (citations omitted). Courts are not to “dismiss a pro

22 se complaint without leave to amend unless ‘it is absolutely clear that the 23 deficiencies of the complaint could not be cured by amendment.’” Rosati v. Igbinoso, 1 791 F.3d 1037, 1039 (9th Cir. 2015) (citing Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th 2 Cir. 2012) (quoting Schucker v. Rockwood, 846 F.2d 1202, 1204 (9th Cir.1988) (per

3 curiam))). But even so, the duties imposed on the Court by § 1915(e) are 4 unwavering, and when an IFP plaintiff fails to state a claim on which relief may be 5 granted, the action must be dismissed.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Alemayehu v. Seattle Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alemayehu-v-seattle-police-department-wawd-2024.