Brickles v. Village of Phillipsburg, Ohio

CourtDistrict Court, S.D. Ohio
DecidedSeptember 20, 2019
Docket3:18-cv-00193
StatusUnknown

This text of Brickles v. Village of Phillipsburg, Ohio (Brickles v. Village of Phillipsburg, Ohio) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brickles v. Village of Phillipsburg, Ohio, (S.D. Ohio 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

TINA BRICKLES, et al., : Case No. 3:18-cv-193 : Plaintiffs, : Judge Thomas M. Rose : v. : : VILLAGE OF PHILLIPSBURG, OHIO, et al., : : Defendants. : ______________________________________________________________________________

ENTRY AND ORDER ACCEPTING, IN PART, AND REJECTING, IN PART, THE AMENDED REPORT AND RECOMMENDATIONS (DOC. 31); OVERRULING, IN PART, AND SUSTAINING, IN PART, DEFENDANTS VILLAGE OF PHILIPSBURG, OHIO AND MARK WYSONG’S OBJECTIONS TO THE MAGISTRATE JUDGE’S AMENDED REPORT AND RECOMMENDATION (DOC. 32); DISMISSING PLAINTIFFS’ SEVENTH, EIGHTTH, TWENTY- SECOND, AND TWENTY-THIRD CLAIMS AGAINST DEFENDANTS VILLAGE OF PHILIPSBURG, OHIO AND MARK WYSONG; AND, DENYING THE REMAINDER OF DEFENDANTS VILLAGE OF PHILIPSBURG AND WYSONG’S MOTION TO DISMISS (DOC. 19) ______________________________________________________________________________

This case is before the Court on Defendants Village of Phillipsburg, Ohio and Mark Wysong’s Objections (Doc. 32) (“Objections”) to the Magistrate Judge’s Amended Report and Recommendations (Doc. 31) (“Report”).1 In the Report, Magistrate Judge Sharon L. Ovington addressed the “Motion to Dismiss Plaintiffs’ Amended Complaint” (Doc. 19) filed by Defendants Village of Phillipsburg, Ohio and Mark Wysong (the “Village Defendants”). In the Report, Magistrate Judge Ovington recommended that the Village Defendants’ Motion to Dismiss (Doc. 19) be granted, in part, and denied in the remaining part. Specifically, she recommended that Claims Seven and Twenty-Two against the Village Defendants be dismissed with prejudice, but

1 On August 5, 2019, the Magistrate Judge issued an initial Report and Recommendations (Doc. 30). However, on August 9, 2019, the Magistrate Judge, sua sponte, issued the Amended Report and Recommendations (Doc. 31) that is now before the Court, thus mooting the initial Report and Recommendations. that the rest of the motion be denied. The Village Defendants filed Objections to the Report (Doc. 32), and the Plaintiffs filed a Memorandum in Opposition to those Objections (Doc. 35). This matter is now ripe for review. The motion addressed in the Report was a dispositive motion, with respect to at least one claim against at least one party. 28 U.S.C. § 636(b); Fed. R. Civ. P. 72(b). Therefore, with respect

to any part of the Report that has been properly objected to by a party, the Court must determine, de novo, those parts. Id. The Court has made that determination and a de novo review of the record in this case. Below, the Court addresses each of the parts of the Report that have been properly objected to by one or more of the parties. The Court adopts the Introduction, Factual Allegations, Rule 12(b)(6) and Plausibility, and Section 1983 and Municipal Liability sections of the Report, which provide a summary of the background facts, the standard for ruling on a motion to dismiss under Fed. R. Civ. P. 12(b)(6), and general legal principles concerning claims for municipal liability brought under 42 U.S.C. § 1983. (Doc. 31 at PAGEID # 302-10.) This Order assumes familiarity with those sections of the

Report. I. Objection to Recommendation Against Dismissing Plaintiffs’ Inadequate Screening Claims (Claims 6 and 21) The Village Defendants argue in their Objections that Plaintiffs’ Inadequate Screening claims against them (Claims 6 and 21) should have been dismissed and that the Report misapplied United States Supreme Court precedent when analyzing the plausibility of those claims. (Doc. 32 at PAGEID # 329-31.) The Village Defendants argue that the Report does not properly apply Board of Cnty. Com’rs of Bryan Cnty., Okl. v. Brown, 520 U.S. 397 (1997) to link Defendant Justin W. Sanderson’s background to the alleged sexual assaults. (Id. at PAGEID # 331.) The Court disagrees with the Village Defendants’ argument, agrees with Magistrate Judge Ovington’s analysis in the Report, and finds that the Report—in line with Brown—“carefully test[ed] the link between the policymaker’s inadequate decision [the municipal action] and the particular injury alleged.” Brown, 520 U.S. at 410. In fact, the Report spends several pages doing so, analyzing the allegations in the Amended Complaint and applying them to the Supreme Court’s

pronouncements in Brown. (Doc. 31 at PAGEID # 312-18.) Accordingly, the Court overrules the Village Defendants’ objections regarding the Report’s recommendation that Claims 6 and 21 are not subject to dismissal under Rule 12(b)(6). The Court adopts the portion of the Report, and accepts its recommendation, regarding those two claims. See Griffin v. City of Opa-Locka, 261 F.3d 1295, 1313-14 (11th Cir. 2001) (evidence produced was sufficient to find deliberate indifference based on inadequate screening given testimony that the city manager was hired without a background check, the city had received information alerting it to problems that the city manager previously had in dealing with women, and a check into his prior employment history would have further alerted the city to prior complaints about him).

II. Objection to Recommendation Against Dismissing Plaintiffs’ Equal Protection Claims (Claims 8 and 23) The Village Defendants also argue in their Objections that Plaintiffs’ Equal Protection claims against them (Claims 8 and 23) should have been dismissed, that they did not waive their argument that Plaintiffs failed to state an equal protection claim, and that the Report incorrectly found that it is premature to dismiss such claims. (Doc. 32 at PAGEID # 331-33.) First, regarding any waiver or abandonment of the Village Defendants’ argument that Plaintiffs’ failed to state an equal protection claim, the Court notes that the Report’s recommendation does not rely on finding abandonment of the argument. (Doc. 31 at PAGEID #323-24.) However, to the extent necessary to address it, this Court disagrees with any proposed finding in the Report that the Village Defendants abandoned (or waived) their argument by not addressing, in their (non-mandatory) Reply brief, Plaintiffs’ contention that the Amended Complaint’s allegations support plausible equal protection claims.2 (Doc. 32 at PAGEID # 332.) Second, this Court disagrees with the Report’s proposed finding that “it is premature to recommend dismissing Plaintiffs’ equal-protection claims” because the Defendants did not

provide “analytical input” on “Plaintiffs’ substantive contention that Phillipsburg discriminated against them on the basis of their gender by failing to provide female detainees a reasonably safe and secure location where they could be processed.” (Doc. 31 at PAGEID # 324.) As set forth in the Report, the “Amended Complaint describes nightmarish crimes perpetrated by Defendant Justin W. Sanderson,” a former police officer for the Village of Phillipsburg who has since been “found guilty in state court of rape, sexual battery, gross sexual imposition, kidnapping, and civil- rights violations.” (Doc. 31 at PAGEID # 302.) The Amended Complaint alleges that Defendant Sanderson, on separate occasions, drove Plaintiffs Tina Brickles and Kelsey Walker to the Phillipsburg municipal building at night and sexually assaulted them there. (Doc. 15.)

The Equal Protection Clause forbids the State from denying to “any person within its jurisdiction the equal protection of the laws.” U.S.

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