Brown v. Smith

CourtDistrict Court, N.D. Alabama
DecidedFebruary 7, 2025
Docket6:24-cv-01001
StatusUnknown

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

Bluebook
Brown v. Smith, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA JASPER DIVISION

KAYSE BROWN, ) ) Plaintiff, ) ) v. ) Case No. 6:24-cv-1001-GMB ) NICK SMITH, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Before the court are two partial motions to dismiss Plaintiff Kayse Brown’s claims against Defendants Sheriff Nick Smith, Carl Carpenter, and Justin White. Docs. 6 & 13. The parties have consented to the jurisdiction of a United States Magistrate Judge pursuant to 28 U.S.C. § 636(c). Doc. 22. The motions are fully briefed (Docs. 7, 14, 17–20) and ripe for decision. For the following reasons, Carpenter and White’s motion (Doc. 6) is due to be denied, while Sheriff Smith’s motion (Doc. 13) is due to be granted in part and denied in part. I. STANDARD OF REVIEW Both motions raise questions about the court’s subject matter jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(1). See Boglin v. Bd. of Trs. of Ala. Agric. & Mech. Univ., 290 F. Supp. 3d 1257, 1261 (N.D. Ala. 2018) (finding that “immunity issues are construed as challenges to the subject-matter jurisdiction of a federal court”). Subject matter jurisdiction is the statutorily conferred power of the court to hear a class of cases. Arbaugh v. Y&H Corp., 546 U.S. 500, 503 (2006).

A motion to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1) takes one of two forms: a “facial attack” or a “factual attack.” Lawrence v. Dunbar, 919 F.2d 1525, 1528–29 (11th Cir. 1990). “Facial attacks challenge subject matter

jurisdiction based on the allegations in the complaint, and the district court takes the allegations as true in deciding whether to grant the motion.” Morrison v. Amway Corp., 323 F.3d 920, 925 n.5 (11th Cir. 2003). On the other hand, “[f]actual attacks challenge subject matter jurisdiction in fact, irrespective of the pleadings. In

resolving a factual attack, the district court may consider extrinsic evidence such as testimony and affidavits.” Id. Smith, Carpenter, and White assert that Brown’s complaint, “on its face, lacks

an adequate basis for subject matter jurisdiction.” Doc. 7 at 2; Doc. 14 at 2. The court therefore is confined to the four corners of Brown’s complaint and will not consider the affidavit (Doc. 7-1) Carpenter and White submitted in support of their motion.

II. RELEVANT FACTS In June 2021, the Recovery Resource Center (“RRC”) hired Brown as a Certified Recovery Specialist. Doc. 1 at 3. The RRC works with the Walker County

Sheriff’s Office (Doc. 1 at 5), and inmates within the Walker County Jail “frequently called Brown’s cell phone to report the conditions in the jail.” Doc. 1 at 6. Smith is the “elected Sheriff of Walker County,” Carpenter is an “employee of the Walker

County Sheriff’s Office,” and White is the “Jail Administrator of the Walker County Jail.” Doc. 1 at 2. After Walker County Jail inmate Tony Mitchell “died of hypothermia and

sepsis caused by neglect and abuse while in the jail” (Doc. 1 at 3), Brown began to advocate for “transparency and better conditions in the Walker County Jail.” Doc. 1 at 4. She formed a group called “Justice for Tony Mitchell,” attended vigils and protests for Mitchell, and reposted messages on Facebook, some of which “were

critical of the way . . . Sheriff Smith’s employees treated Mitchell and other inmates.” Doc. 1 at 4. In March 2024, a little more than a year after Mitchell’s death, Carpenter

texted RRC Director John Bales. Doc. 1 at 4. He asked Bales to attend “a meeting with the Sheriff about Brown’s employment” and attached some of her Facebook posts to his text message. Doc. 1 at 4. Bales told Brown about the messages the next day and mentioned “that he was going to have a call with the Sheriff.” Doc. 1 at 4.

During the call, “the Sheriff told Bales that he did not like that Brown was advocating for Mitchell.” Doc. 1 at 4. Separately, someone at the Sheriff’s Office mentioned the contract between the Walker County Jail and RRC to Bales and told

her (1) the Sheriff’s Office knows “‘how valuable the RRC is,’ but that it’s ‘gotten really hard to separate’ it from [her] advocacy regarding Tony Mitchell’s death”; (2) “the bridges aren’t burned, but they seem to be smoldering”; and (3) the Sheriff’s

Office would “‘appreciate [her] help putting it out’ on his side.” Doc. 1 at 8. After Bales told Brown that he “had talked to the Sheriff and or Carpenter and Smith about her employment,” he also told her “that she needed to ‘be careful.’”

Doc. 1 at 5. Brown responded that she thought the Sheriff’s Office was “trying to make her lose her job” because of her advocacy for Mitchell, and Bales said that “he ‘will validate that thought, because that’s the reality of it.’” Doc. 1 at 9. Sheriff Smith and Brown’s husband also spoke on the phone. Doc. 1 at 12.

During this call, Sheriff Smith said, “I am getting to the point where, if that’s how things are going, I mean, we can call people’s bosses or do that kind of thing as well.” Doc. 1 at 12. Meanwhile, White “wrote correspondence to Brown’s

employer,” stating that “Brown’s advocacy was threatening her employer’s relationship with the Walker County Sheriff’s office,” and urging her employer to “take action against her.” Doc. 1 at 5 & 9. In May 2024, Bales terminated Brown’s employment with the RRC because

of “a complaint from the ‘Partner Community.’” Doc. 1 at 5. Following her termination, Carpenter and White notified all of the female inmates at the Walker County Jail that Brown had been terminated from the RRC. Doc. 1 at 6. Carpenter

and White also told the inmates that they “should not trust Brown, because she was not who she said she was.” Doc. 1 at 6. Carpenter, White, and Smith then blocked the inmates from making any more calls to Brown. Doc. 1 at 6.

Brown filed her complaint against Smith in his official and individual capacities, Carpenter in his individual capacity, and White in his individual capacity. Brown’s complaint includes the following counts against all defendants: (1) a First

Amendment retaliation claim brought under 42 U.S.C. § 1983; (2) a state-law tortious interference claim; (3) a claim for violations of Article I, Section 4 of the Alabama Constitution; and (4) a state-law wantonness claim. Doc 1. at 6–16. Sheriff Smith moves to dismiss all claims against him in his official capacity, arguing he is

entitled to immunity under the Eleventh Amendment. Doc. 13. Smith, Carpenter, and White move to dismiss the state-law claims against them in their individual capacities, arguing they are entitled to State immunity under the Alabama

Constitution. Docs. 6 & 13. Only the claims against Sheriff Smith in his official capacity will be dismissed. III. DISCUSSION The court begins by analyzing the official capacity claims against Sheriff

Smith and then addresses the individual capacity claims against all three defendants. A. Official Capacity Claims Against Sheriff Smith Smith argues that the claims brought against him in his official capacity

should be dismissed. Doc. 14 at 5. Specifically, he contends that these claims are barred by the Eleventh Amendment to the United States Constitution. Doc. 14 at 5. The Eleventh Amendment provides that the “Judicial power of the United

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