Bonning v. Idaho State Police Department

CourtDistrict Court, D. Idaho
DecidedApril 7, 2025
Docket1:25-cv-00002
StatusUnknown

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

Bluebook
Bonning v. Idaho State Police Department, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

AMY ROSE INGRAM BONNING, Case No. 1:25-cv-00002-AKB Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

IDAHO STATE POLICE DEPARTMENT; BRAD LITTLE; BRANDON WOLF; PHIL MCGRANE; ASHLEY DOWELL; JOSH TEWALT; TERESA JONES; DAVE JESPEN; ALEX ADAMS; STEVEN BARTLETT; MATTHEW CLIFFORD; STEVEN HIPPLER; ADA COUNTY COMMISSIONERS DEPARTMENT; ADA COUNTY JAIL INVESTIGATOR DEPUTY HANSON; JAN BENNITS; JOSH HURWIT; and RYAN O’NIEL,

Defendants.

The Clerk of Court conditionally filed Plaintiff Amy Rose Ingram Bonning’s Complaint because of Plaintiff’s status as an inmate and in forma pauperis request. A “conditional filing” means that a plaintiff must obtain authorization from the Court to proceed. Upon screening, the Court must dismiss claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). Having reviewed the record, the Court concludes that the Complaint fails to state a claim upon which relief may be granted. Accordingly, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed. 1. Standards of Law for Screening Complaints A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). To state an actionable claim, a plaintiff must provide “enough factual matter (taken as true) to suggest” that the defendant committed the unlawful act, meaning that sufficient facts are pled “to raise a reasonable expectation that discovery will reveal evidence of illegal [activity].” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Iqbal, 556 US. at 678 (quoting Twombly, 550 U.S. at 555). The Court liberally construes the pleadings to determine whether a case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional claim,

however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000). Moreover, even if a complaint meets the pleading requirements, dismissal under §§ 1915 and 1915A is still appropriate if an affirmative defense is an “obvious bar to securing relief on the face of the complaint.” Washington v. Los Angeles Cnty. Sheriff’s Dep’t, 833 F.3d 1048, 1056 (9th Cir. 2016) (internal quotation marks omitted). 2. Factual Allegations Plaintiff is an inmate in the Ada County Jail. Because Plaintiff’s Complaint contains no dates, and names as defendants current and former county, state, and federal officials, it is unclear from the Complaint whether Plaintiff was in county, state, or federal custody at the time her claims arose.

Plaintiff states she has been raped multiple times while in custody and that her custodians failed to protect her from those assaults. (Compl., Dkt. 3, at 4, 6). Plaintiff alleges Defendants have not accurately reported sexual assault data as required by the Prison Rape Elimination Act, 34 U.S.C. § 30302 et seq. (“PREA”). (Compl., Dkt 3, at 4, 6). Plaintiff also contends Defendants’ actions constitute illegal activity by an organized criminal enterprise under Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961, et seq. (Compl., Dkt. 3, at 2, 4). Finally, Plaintiff claims Defendants’ actions violated federal and state criminal statutes. (Id. at 1, 7). 3. Discussion The Complaint fails to link any particular Defendant to any particular action and does not

state a claim upon which relief may be granted. The Court will, however, grant Plaintiff twenty- eight days to amend the Complaint. Any amended complaint should take into consideration the following. A. Section 1983 Claims Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. (Compl. at 1). To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). A defendant causes a constitutional deprivation within the meaning of § 1983 “if he does an affirmative act, participates in another’s affirmative acts, or omits to perform an act which he is legally required to do that causes the deprivation.” Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). That is, prison officials generally are not liable for damages in their individual capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach Government

official, his or her title notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does not allow for recovery against an employer or principal simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045. Personal liability under § 1983 “cannot be based on prison conditions beyond the control of a defendant.” Pinto v. Nettleship, 737 F.2d 130, 133 (1st Cir. 1984). However, “[a] defendant may be held liable as a supervisor under § 1983 ‘if there exists . . . a sufficient causal connection between the supervisor’s wrongful conduct and the constitutional violation.’” Starr v. Baca, 652 F.3d 1202, 1207 (9th Cir. 2011) (quoting Hansen v. Black, 885 F.2d 642, 646 (9th Cir. 1989)). A plaintiff can establish this causal connection by alleging a defendant

(1) set in motion a series of acts by others that violated the Constitution, or knowingly refused to terminate a series of such acts, which the supervisor “knew or reasonably should have known would cause others to inflict a constitutional injury”; (2) knowingly failed to act or acted improperly “in the training, supervision, or control of his subordinates”; (3) acquiesced in the constitutional deprivation; or (4) engaged in conduct showing “a reckless or callous indifference to the rights of others.” Id.

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Bonning v. Idaho State Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bonning-v-idaho-state-police-department-idd-2025.