Austin v. Franklin County, Kentucky

CourtDistrict Court, E.D. Kentucky
DecidedJuly 26, 2024
Docket3:22-cv-00068
StatusUnknown

This text of Austin v. Franklin County, Kentucky (Austin v. Franklin County, Kentucky) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Austin v. Franklin County, Kentucky, (E.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION FRANKFORT

ANTHONY W. AUSTIN, ) ) Plaintiff, ) Case No. 3:22-cv-00068-GFVT ) v. ) ) MEMORANDUM OPINION FRANKLIN COUNTY, KENTUCKY, ) & et al., ) ) ORDER Defendants. ) ) *** *** *** *** This matter is before the Court on three Motions to Dismiss filed by the Defendants. [R. 25; R. 26; R. 27.] Mr. Austin alleges that the Defendants, all of whom are connected to the Franklin County Sherriff’s Office, violently assaulted him multiple times on New Year’s Day in 2020. [R. 1-1.] All the Defendants argue that Mr. Austin’s complaint, filed nearly three years after that conduct, is untimely. [R. 25; R. 26; R. 27.] Mr. Austin asks the Court to find that the statute of limitations was tolled because the Defendants’ conduct rendered him incapable of managing his own affairs. [R. 30; R. 31.] Because the Complaint does not plead sufficient grounds to toll the statute of limitations, the Court GRANTS the Defendants’ Motions to Dismiss [R. 25; R. 26; R. 27]. I On January 1, 2020, Mr. Austin was involved in a series of alcohol-fueled disputes with his housemates.1 [R. 23 at 4.] One housemate called the Franklin County Sheriff's Office on

1 Because the Amended Complaint is substantially similar to the original Complaint, these facts are taken from the Court’s prior Memorandum Opinion and Order at [R. 22]. Mr. Austin “four times that day.” Id. at 5. The fourth time, deputies arrested Mr. Austin and he “did not cooperate in being taken away.” Id. He states that the deputies “physically assaulted, subdued and handcuffed [him], and carried his unconscious body to a FCSO cruiser.” Id. He believes that one deputy kneed him in the temple but has no personal memory of the subsequent

events. Id. at 5. Once Mr. Austin was in the cruiser, he regained consciousness. Id. He states that “the cruiser rocked and bucked as the deputies assaulted [him]” while he was handcuffed. Id. Mr. Doty, a sergeant at the time, drove him to the Frankfort Regional Medical Center, where he was handcuffed to a bed in the emergency room. Id. Mr. Austin was “upset and irritated and may have used a racial slur to refer to a negro Deputy in the room.” Id. at 6. Mr. Doty “severely chastised” him “and then violently assaulted him, in the presence of the other Deputies in the room.” Id. Mr. Austin states that this incident was captured on body cameras. Id. He states that Mr. Doty attempted to strangle and suffocate him during the encounter. Id. After Mr. Austin received treatment, Mr. Doty drove him to the jail. Id. Mr. Austin was ultimately

charged with menacing, first degree resisting arrest, and disorderly conduct. Id. Mr. Austin states that none of the officers filed a Use of Force Report or reported observing excessive force, which the Department would require in this situation. Id. Mr. Austin had no recollection of the events and suspected that his blackouts and injuries were from consuming alcohol. Id. at 6-7. He discovered the events in November 2021, when a relative who worked for the Frankfort Police IT department informed him that a video of the encounter existed. Id. at 7. He filed an open records request, which was denied but triggered an internal review of the interaction. Id. Sheriff Quire reviewed the body camera footage and fired Mr. Doty. Id. at 8. Mr. Austin has since been given access to the videos but claims that one is missing. Id. In August 2023, the Court granted Mr. Austin leave to file an amended complaint. [R. 22.] Mr. Austin filed an amended complaint on September 21, 2023. [R. 23.] In his First

Amended Complaint, Mr. Austin includes additional factual assertions at paragraphs 27, 28, and 29 in a seeming attempt to provide a basis for why the statute of limitations should be tolled. Id. Mr. Austin claims that he “suffered considerable mental and physical pain and suffering” because of the assault. Id. at 9-10. He was diagnosed with “a traumatic brain injury and occipital neuralgia and a variety of related problems, including memory loss, and a progressively deteriorating memory.” Id. Thus, the Plaintiff argues, he “was of unsound mind and remains of unsound mind as a result of his injuries suffered at the hands of the Defendants,” such that “[t]he statute of limitations was tolled until such time as Plaintiff uncovered the cause of his injuries.” Id. at 10-11. He brings a number of claims against the Defendants under the U.S. Constitution and Kentucky law. Id. at 10-12. Across the three Motions to Dismiss, each Defendant seeks

dismissal of the Complaint in its entirety. [R. 25; R. 26; R. 27.] II The Motions to Dismiss are all brought pursuant to Rule 12(b)(6), which tests the sufficiency of a plaintiff’s complaint. In reviewing a Rule 12(b)(6) motion, the Court “construe[s] the complaint in the light most favorable to the plaintiff, accept[s] its allegations as true, and draw[s] all inferences in favor of the plaintiff.” DirecTV, Inc. v. Treesh, 487 F.3d 471, 476 (6th Cir. 2007) (citation omitted). The Court, however, “need not accept as true legal conclusions or unwarranted factual inferences.” Id. (quoting Gregory v. Shelby Cnty., 220 F.3d 433, 446 (6th Cir. 2000)). The Supreme Court explained that in order “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Courier v. Alcoa Wheel & Forged Products, 577 F.3d 625, 629 (6th Cir. 2009).

Moreover, the facts that are pled must rise to the level of plausibility, not just possibility; “facts that are merely consistent with a defendant’s liability . . . stop[ ] short of the line between possibility and plausibility.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 557 (2007)). According to the Sixth Circuit, “[a] claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). A The Motions to Dismiss primarily argue that Mr. Austin’s claims should be dismissed because they fall outside the statute of limitations. [R. 25-1 at 4; R. 26-1 at 2; R. 27-1 at 4.] All

of Mr. Austin’s claims, state and federal alike, are governed by a one-year limitations period. Section 1983 does not provide its own limitations period, so federal courts borrow the most analogous statute of limitations from the state where the events occurred. Zundel v. Holder, 687 F.3d 271, 281 (6th Cir. 2012). In Kentucky, that statute is Ky. Rev. Stat. § 413.140(1)(a), which establishes a one-year limitations period for personal injuries. Bonner v. Perry, 564 F.3d 424, 430-31 (6th Cir. 2009). The parties agree that this limitations period applies to Mr. Austin’s claims. [R. 25-1 at 4; R. 26-1 at 2; R. 27-1 at 4.]; see also Collard v. Ky. Bd. of Nursing, 896 F.2d 179 (6th Cir. 1990) (claims brought in Kentucky under 42 U.S.C.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ernst Zundel v. Eric Holder, Jr.
687 F.3d 271 (Sixth Circuit, 2012)
Regis Lutz v. Chesapeake Appalachia, L.L.C.
717 F.3d 459 (Sixth Circuit, 2013)
Bonner v. Perry
564 F.3d 424 (Sixth Circuit, 2009)
Courie v. Alcoa Wheel & Forged Products
577 F.3d 625 (Sixth Circuit, 2009)
Southeastern Kentucky Baptist Hospital, Inc. v. Gaylor
756 S.W.2d 467 (Kentucky Supreme Court, 1988)
Roman Catholic Diocese of Covington v. Secter
966 S.W.2d 286 (Court of Appeals of Kentucky, 1998)
Cranston Reid v. Gerald Baker
499 F. App'x 520 (Sixth Circuit, 2012)
Green v. Floyd County
803 F. Supp. 2d 652 (E.D. Kentucky, 2011)

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Bluebook (online)
Austin v. Franklin County, Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/austin-v-franklin-county-kentucky-kyed-2024.