Battle v. Rowe

CourtDistrict Court, E.D. North Carolina
DecidedMarch 14, 2025
Docket5:24-cv-00353
StatusUnknown

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

Bluebook
Battle v. Rowe, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION

NO. 5:24-CV-353-FL

KAREN A. BATTLE, ) ) Plaintiff, ) ) v. ) ) WAKE COUNTY SHERIFF’S OFFICE, ) ORDER WILLIE ROWE in his official capacity as ) SHERIFF OF WAKE COUNTY, and ) UNKNOWN SURETY COMPANY, as ) surety, ) ) Defendants. )

This matter is before the court upon defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) (DE 16). For the following reasons, the motion is granted in part and denied in part. STATEMENT OF THE CASE Plaintiff commenced this action June 24, 2024, asserting three claims: 1) sex discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000(e) et seq., (“Title VII”); 2) intentional infliction of emotional distress under North Carolina law; and 3) violation of the Equal Protection Clause under 42 U.S.C. § 1983. Plaintiff seeks compensatory damages, and attorneys’ fees and costs. Defendants filed the instant motion to dismiss two of plaintiff’s three claims for failure to state a claim upon which relief can be granted, on September 18, 2024. In particular, defendants seek to “dismiss this action in its entirety as to defendant denominated by plaintiff as ‘Wake County Sheriff’s Office’ and to dismiss Counts II and II [sic] against defendant Willie Rowe, in his official capacity as Sheriff of Wake County[.]” (Defs’ Mot. (DE 16) at 1).1 Plaintiff responded in opposition. STATEMENT OF FACTS The facts alleged in the complaint are as follows. Plaintiff is a white female who resided

in Raleigh, North Carolina, and who began working for the Wake County Sheriff’s Office in 1997. (Compl. (DE 1) ¶¶ 1, 14). Gerald Baker (“Baker”) was the sheriff of Wake County from December 2018 through December 2022. (Id. ¶ 3). Defendant Willie Rowe currently holds that office. (Id. ¶ 2). The Wake County Sheriff’s Office employed plaintiff beginning in August 1997, and she received successive promotions eventually to the level of major. (Id. ¶ 14–15). Plaintiff was the first female major in office history to be assigned to Patrol Division. (Id. ¶ 16). At an unspecified time, Baker “became upset” with a female deputy for allowing the Raleigh Police Department to assist on a call, despite the absence of any jurisdictional conflict.

(Id. ¶¶ 18–19). Baker ordered plaintiff to transfer the deputy “to the evidence room” as a form of punishment. (Id. ¶ 20). Baker demoted plaintiff to lieutenant, and plaintiff alleges that he used assignment to the evidence room as a form of punishment, including against plaintiff following this demotion. (Id. ¶ 21). Baker also 1) excluded plaintiff from community events, and permitted only male majors to attend; 2) listed only male majors in operational documents for protest coverage in June 2022;

1 The court infers from defendants’ filings that the motion is directed against counts II and III. Defendants’ motion requests dismissal of all claims against the Wake County Sheriff’s Office, on grounds that it is not a suable entity. (See Mot. Dismiss (DE 16). However, the motion requests dismissal, as noted, only of “counts II and II [sic] against defendant Willie Rowe[.]” (Id.). Defendants’ briefing does not engage with plaintiff’s first claim, under Title VII, whatsoever. (See generally Defs’ Br. (DE 17)). The court therefore infers from defendants’ motion and briefing that they do not challenge plaintiff’s first claim, notwithstanding the language in the conclusions of defendants’ motion and supporting memorandum requesting dismissal of the complaint as a whole. (See Mot. Dismiss 2; Defs’ Br. 11). and 3) demoted plaintiff following a false, anonymous complaint of timesheet falsification after refusing to investigate or allow plaintiff to defend herself. (Id. ¶¶ 30–39). Baker permitted a male lieutenant accused of the same infraction to defend himself, and did not demote him. (Id. ¶ 40). Baker also carried out plaintiff’s demotion publicly via an agency-wide email to embarrass plaintiff. (Id. ¶ 42).

Baker created an entirely new division and placed plaintiff there, away from the work she was accustomed to, while also decreasing plaintiff’s responsibilities and assigning a male major to co-manage plaintiff’s patrol division post, which the sheriff’s office had never done before. (See id. ¶¶ 46–48). Baker also made plaintiff move her office to share with two subordinate officers, whereas all male majors retained their own individual offices. (Id. ¶¶ 54–55). Baker demoted plaintiff again on July 24, 2022, along with two males, though the male officers’ demotions were rescinded four days afterwards. (Id. ¶¶ 58–59). Plaintiff alleges their demotions were merely to create an appearance of impartiality. (Id. ¶ 58). Baker also threatened plaintiff with termination for not knowing whether a missing person

was a veteran “within minutes of the call arriving to her,” and threatened plaintiff that she would not remain employed with the sheriff’s office for another three years. (Id. ¶¶ 62–63, 70). Finally, Baker demoted plaintiff a third time from major to detention officer. (Id. ¶¶ 74–75). Plaintiff has been unable to secure another law enforcement position since that time, despite her qualifications. (Id. ¶ 77). COURT’S DISCUSSION A. Standard of Review To survive a motion to dismiss under Rule 12(b)(6), “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, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “Factual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. In evaluating whether a claim is stated, “[the] court accepts all well- pled facts as true and construes these facts in the light most favorable to the plaintiff,” but does not consider “legal conclusions, elements of a cause of action, . . . bare assertions devoid of further

factual enhancement[,] . . . unwarranted inferences, unreasonable conclusions, or arguments.” Nemet Chevrolet, Ltd. v. Consumeraffairs.com, Inc., 591 F.3d 250, 255 (4th Cir. 2009). B. Analysis Defendants assert that 1) the Wake County Sheriff’s Office is not a suable entity; 2) plaintiff fails to allege conduct actionable as intentional infliction of emotional distress; and 3) her Equal Protection Clause claim is really a municipal liability claim against Wake County, and fails to set out any custom or policy as required. For the following reasons, the court agrees with defendants as to Wake County Sheriff’s Office’s non-susceptibility to suit, and that she cannot maintain claim for intentional infliction of emotional distress. The court disagrees, however, with

defendants’ arguments directed towards plaintiff’s Equal Protection Clause claim. 1. Wake County Sheriff’s Office Defendants first argue that any claim presented against the Wake County Sheriff’s Office cannot succeed. Defendants are correct. The law of the state in which a federal court sits governs the susceptibility to suit of governmental entities. Avery v. Burke Cnty., 660 F.2d 111, 113–14 (4th Cir. 1981). Under North Carolina law, sheriff’s departments are not subject to suit. See Treadway v. Diez, 209 N.C. App. 152, 156–58 (2011) (Jackson, J., dissenting), rev’d for reasons stated in dissent, 365 N.C.

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Bluebook (online)
Battle v. Rowe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/battle-v-rowe-nced-2025.