Allen v. Nelson

CourtDistrict Court, W.D. Washington
DecidedMarch 8, 2022
Docket2:21-cv-01097
StatusUnknown

This text of Allen v. Nelson (Allen v. Nelson) 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
Allen v. Nelson, (W.D. Wash. 2022).

Opinion

5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 JOSEPH ALLEN, 8 No. 2:21-cv-1097-BJR 9 Plaintiff, v. ORDER ON DEFENDANTS’ MOTION 10 FOR STAY OF PROCEEDINGS JEFF NELSON, et al., 11

12 Defendants.

13 This matter comes before the Court on Defendants’ Motion for Stay of Proceedings. Dkt. 14 No. 14. Having reviewed the materials submitted by the parties and the balance of the record in 15 16 this case, the Court DENIES the motion. The reasons for the Court’s decision are set forth 17 below. 18 I. Background 19 Plaintiff Joseph Allen filed this action on August 16, 2021, against Defendants Jeff 20 Nelson, the City of Auburn, and the Auburn Police Department. Plaintiff’s claims arise from his 21 arrest on August 23, 2018, by Defendant Nelson, who was an officer of the City of Auburn 22 Police Department. 23 24 Plaintiff’s complaint raises federal claims against all defendants for excessive force and 25 unlawful seizure, as well as state-law claims for outrage, negligence, and violation of the 26 Washington Law Against Discrimination, RCW 49.60. Plaintiff has also brought Monell claims

ORDER - 1 1 against the City of Auburn for violation of his constitutional rights, alleging that the City violated 2 its duty to use reasonable care in hiring, training, and supervising its employees and agents. This 3 case is currently scheduled for trial on January 9, 2023, with a discovery deadline of July 13, 4 2022. 5 Plaintiff’s complaint includes allegations that Defendant Nelson “has shot and killed 6 three people during his tenure as an Auburn Police Officer” and that Defendant Nelson “is 7 currently charged with Murder in the second degree for the killing of Jesse Sarey.” Dkt. No. 1 at 8 9 4. Defendants indicate that Defendant Nelson’s criminal trial in State v. Nelson is scheduled for 10 June 27, 2022, in King County Superior Court. Defendants also indicate that it is possible that 11 Defendant Nelson could face criminal charges for another deadly force incident (referred to by 12 Defendants as the “Obet incident”) in which Defendant Nelson shot a man in 2017. 13 Defendant Nelson has moved to stay all proceedings in this matter until his “criminal 14 prosecution has finally concluded.” Dkt. No. 14 at 3; see also Dkt. No. 14-1 at 2 (proposing that 15 16 the Court order that “[n]o further action shall occur in this matter until Defendant Nelson’s 17 criminal matter is fully and finally resolved.”). In the alternative, Defendant Nelson requests “a 18 stay limited to discovery propounded to him or a similar protective order.” Dkt. No. 14 at 13. 19 The City of Auburn joins in Defendant Nelson’s motion. 20 II. Discussion 21 A. Request to Stay Case in Its Entirety 22 “The Constitution does not ordinarily require a stay of civil proceedings pending the 23 24 outcome of criminal proceedings.” Keating v. Office of Thrift Supervision, 45 F.3d 322, 324 (9th 25 Cir. 1995). However, a court has discretion to stay civil proceedings when the interests of justice 26 so require. Id. “The decision whether to stay civil proceedings in the face of a parallel criminal

ORDER - 2 1 proceeding should be made ‘in light of the particular circumstances and competing interests 2 involved in the case.’” Id. (quoting Fed’l Sav. & Loan Ins. Corp. v. Molinaro, 889 F.2d 899, 902 3 (9th Cir. 1989)). 4 To determine whether to stay a civil proceeding in light of a pending criminal 5 proceeding, the Ninth Circuit has held that the trial court should consider: (1) the extent to which 6 the defendant’s Fifth Amendment rights are implicated; (2) the interest of the plaintiff in 7 proceeding expeditiously with the civil litigation or any particular aspect of it, and the potential 8 9 prejudice to plaintiff of a delay; (3) the burden which any particular aspect of the proceedings 10 may impose on the defendant; (4) the convenience of the court in managing its cases and the 11 efficient use of judicial resources; (5) the interests of persons not parties to the civil litigation; 12 and (6) the interest of the public in the pending civil and criminal litigation. Keating, 45 F.3d at 13 324. The Court considers these factors in turn below. 14 1. Extent to Which Defendants’ Fifth Amendment Rights are Implicated 15 16 Defendants argue that Defendant Nelson’s Fifth Amendment right against self- 17 incrimination is directly implicated in this case. Defendants argue that Plaintiff has alleged that 18 the deadly force incident at issue in State v. Nelson is relevant to his Monell claims. Defendants 19 also maintain that the prosecution in State v. Nelson will attempt to introduce evidence regarding 20 Defendant Nelson’s use of force during Plaintiff’s arrest, and that as a result Defendant Nelson 21 cannot respond to discovery or testify in this matter without implicating his Fifth Amendment 22 rights in the criminal proceeding. Defendants also maintain that “many questions concerning 23 24 training and police policy are at issue in both cases.” Dkt. No. 14 at 5. In addition, Defendants 25 argue that Plaintiff is likely to seek discovery responses from Defendant Nelson regarding the 26

ORDER - 3 1 2017 Obet deadly force incident, which raises Fifth Amendment implications because Defendant 2 Nelson could still be subject to criminal charges related to that incident. 3 In response, Plaintiff points out that Defendant Nelson is not the only defendant in this 4 case. Plaintiff notes that the City of Auburn and the Auburn Police Department are also 5 defendants in this action and do not have any Fifth Amendment rights that are implicated here. 6 Plaintiff also argues that this civil case and State v. Nelson are “not significantly overlapping” 7 and notes that Defendant Nelson “is not going on trial for the acts he committed against the 8 9 Plaintiff here.” Dkt. No. 21 at 2. 10 It is not clear to the Court how substantially the issues in this case may or may not 11 ultimately overlap with the issues in State v. Nelson. The criminal case involves charges arising 12 from an entirely different incident than this civil case, and it is unclear to the Court that the 13 prosecution in State v. Nelson would be permitted to offer evidence regarding Defendant 14 Nelson’s conduct toward Plaintiff. In any event, as Plaintiff notes, Defendant Nelson is not the 15 16 only defendant in this case, and Defendants City of Auburn and Auburn Police Department do 17 not have Fifth Amendment rights to assert in this matter. As a result, the Court finds that this 18 factor does not weigh in favor of staying this case in its entirety pending the resolution of 19 criminal proceedings against Defendant Nelson. Any possible implications of Defendant 20 Nelson’s Fifth Amendment rights in this matter do not warrant bringing the entire case to a halt 21 pending the final resolution of Defendant Nelson’s criminal case. 22 2. Plaintiff’s Interests 23 24 The Court next considers Plaintiff’s interests in proceeding expeditiously with the civil 25 litigation or any particular aspect of it, and the potential prejudice to Plaintiff resulting from a 26 delay. Here, Plaintiff has a strong interest in proceeding expeditiously with his case. Plaintiff’s

ORDER - 4 1 counsel has represented that Plaintiff has stage five kidney disease. Plaintiff also has a financial 2 interest in providing for his family members through a potential recovery of damages in this 3 case. The Court finds that this factor weighs against staying this case in its entirety. 4 3.

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Bluebook (online)
Allen v. Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-nelson-wawd-2022.