Branson v. Shawnee County, Kansas, Board of Commissioners

CourtDistrict Court, D. Kansas
DecidedJune 27, 2025
Docket2:25-cv-02025
StatusUnknown

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

Bluebook
Branson v. Shawnee County, Kansas, Board of Commissioners, (D. Kan. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

JAN BRANSON, Individually as survival ) heir-at-law and as Special Administrator ) of the Estate, et al., ) ) Plaintiffs, ) CIVIL ACTION v. ) ) No. 25-2025-KHV BOARD OF COUNTY COMMISSIONERS, ) SHAWNEE COUNTY, KANSAS d/b/a ) SHAWNEE COUNTY ADULT DETENTION ) CENTER, et al., ) ) Defendants. ) ___________________________________________)

MEMORANDUM AND ORDER

On January 17, 2025, the survivors of Matthew C. Olivia, who was detained at the Shawnee County Kansas Adult Detention Center, and the special administrator of his estate, filed suit under 42 U.S.C. § 1983. They seek to recover money damages for violation of Mr. Olivia’s rights under the Eighth and Fourteenth Amendments of the United States Constitution and negligence under state law. Specifically, plaintiffs allege that various entities and individuals associated with the detention center were deliberately indifferent to Mr. Olivia’s serious medical needs and failed to provide adequate medical care and treatment. This matter is before the Court on Armor Health Holdings, LLC’s Motion To Dismiss Action Pursuant To Federal Rule Of Civil Procedure 12(b) (Doc. #29) filed March 21, 2025. For reasons stated below, the Court sustains defendant’s motion but grants plaintiffs leave to file a motion to amend their complaint. Legal Standards Rule 12(b)(2), Fed. R. Civ. P., governs motions to dismiss for lack of personal jurisdiction. Plaintiffs bear the burden of establishing a prima facie showing of personal jurisdiction. XMission, L.C. v. PureHealth Rsch., 105 F.4th 1300, 1314 (10th Cir. 2024). At the motion to dismiss stage, plaintiffs’ burden to establish personal jurisdiction is light. Id. Plaintiffs may defeat a motion to dismiss by presenting evidence—either uncontested allegations in their complaint or evidence in the form of an affidavit or declaration—that if true would support jurisdiction over defendant. Eighteen Seventy, LP v. Jayson, 32 F.4th 956, 965 (10th Cir. 2022). In determining

whether plaintiffs have satisfied their burden, the Court takes as true all plausible, nonconclusory facts alleged in the complaint and must resolve any factual disputes in favor of plaintiffs. XMission, 105 F. 4th at 1307. Factual Background I. Plaintiffs’ Complaint Highly summarized, plaintiffs’ Complaint (Doc. #1) filed January 17, 2025, alleges as follows: Armor Health Holdings, LLC (“AHH”) is “legally registered” as Armor Health Management, LLC and Armor Health of Shawnee County, LLC. The three Armor defendants

contracted with Shawnee County to provide necessary healthcare services to detainees at the Shawnee County Adult Detention Center (“Shawnee County ADC”). On October 22, 2023, in Topeka, Kansas, officers arrested Matthew Olivia who was suffering from an acute mental health crisis, and officers transported him to the Shawnee County ADC. Mr. Olivia died because AHH and others failed to provide appropriate medical and mental health care. II. Declaration Of Otto Campo AHH has submitted the affidavit of Otto Campo, the Chief Executive Officer of AHH. See Declaration Of Otto Campo In Support Of Armor Health Holdings, LLC’s Motion To Dismiss (Doc. #32-1) filed March 21, 2025. Mr. Campo states as follows: AHH is a limited liability company which is incorporated in Florida. AHH is not registered in Kansas or elsewhere as Armor Health Management, LLC or Armor Health of Shawnee County, LLC. AHH is a holding company and owns Armor Health of Shawnee County, which was the only Armor entity that contracted with Shawnee County to provide healthcare services. AHH has

no offices, employees or agents in Kansas and has never engaged in business activity in Kansas. III. Procedural Background On January 17, 2025, the survivors of Mr. Olivia and the special administrator of his estate filed suit under 42 U.S.C. § 1983. As to the three Armor defendants, plaintiffs allege that they were deliberately indifferent to Mr. Olivia’s serious medical needs and negligently failed to provide adequate medical care and treatment. Analysis AHH asserts that this Court must dismiss plaintiffs’ claims for lack of personal jurisdiction.1 Specifically, AHH argues that plaintiffs have not alleged that it has sufficient

contacts with Kansas to establish that this Court has personal jurisdiction. Plaintiffs argue that based on AHH’s control of its subsidiary, Armor Health of Shawnee County, the Court has personal jurisdiction over AHH. For the Court to exercise personal jurisdiction, plaintiffs must show that personal jurisdiction is proper under the laws of the forum state and that doing so comports with the due process requirements of the United States Constitution. See Newsome v. Gallacher, 722 F.3d 1257, 1264 (10th Cir. 2013). The Kansas long-arm statute permits the exercise of any jurisdiction

1 AHH also seeks to dismiss plaintiffs’ complaint for lack of standing under Rule 12(b)(1) of the Federal Rules of Civil Procedure. Because plaintiffs’ complaint does not sufficiently allege personal jurisdiction over AHH, the Court need not reach the issue of standing. that is consistent with the United States Constitution. See Federated Rural Elec. Ins. Corp. v. Kootenai Elec. Coop., 17 F.3d 1302, 1304–05 (10th Cir. 1994); see also K.S.A. § 60-308(b)(1)(L). Accordingly, the Court need not conduct a separate personal jurisdiction analysis under Kansas law and may proceed directly to the due process inquiry. See Niemi v. Lasshofer, 770 F.3d 1331, 1348 (10th Cir. 2014) (where long-arm statute confers maximum jurisdiction consistent with Due

Process Clause, statutory inquiry effectively collapses into constitutional analysis). The due process analysis requires the Court to determine (1) whether AHH has “minimum contacts” with the forum state such that it should “reasonably anticipate being haled into court there,” World– Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980), and (2) if AHH’s actions establish minimum contacts, whether the exercise of personal jurisdiction “offends traditional notions of fair play and substantial justice.” Asahi Metal Indus. Co. v. Super. Ct., 480 U.S. 102, 113 (1987). Here, AHH argues that plaintiffs have not established that it had minimum contacts with Kansas. To satisfy the minimum contacts standard, plaintiffs can establish that the Court has either

(1) specific jurisdiction or (2) general jurisdiction. See XMission, 105 F.4th at 1308. Plaintiffs assert only that the Court has specific jurisdiction over AHH. The Court has specific jurisdiction if AHH “purposely directed” its activities at residents of the forum state, and plaintiffs’ alleged injuries “arise out of” those forum-related activities. Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063, 1071 (10th Cir. 2008).

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Related

World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Dudnikov v. Chalk & Vermilion Fine Arts, Inc.
514 F.3d 1063 (Tenth Circuit, 2008)
Newsome v. Gallacher
722 F.3d 1257 (Tenth Circuit, 2013)
Niemi v. Lasshofer
770 F.3d 1331 (Tenth Circuit, 2014)

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Branson v. Shawnee County, Kansas, Board of Commissioners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/branson-v-shawnee-county-kansas-board-of-commissioners-ksd-2025.