Carroll v. Douglas County

CourtDistrict Court, D. Nebraska
DecidedOctober 1, 2021
Docket8:21-cv-00233
StatusUnknown

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

Bluebook
Carroll v. Douglas County, (D. Neb. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

JARON L. CARROLL,

Plaintiff, 8:21-CV-233

vs. MEMORANDUM AND ORDER DOUGLAS COUNTY, Nebraska; MICHAEL MYERS, and JOHN DOES 1-7, individuals being sued in their individual and official capacity,

Defendants.

I. INTRODUCTION Jaron L. Carroll has sued Douglas County, Nebraska (“Douglas County”), Michael Myers, several unnamed Douglas County corrections officers, and an unnamed nurse pursuant to 42 U.S.C. § 1983 for violating his constitutional rights under the Fourth, Sixth, and Fourteenth Amendments. Filing 1. Before the Court is Douglas County and Myers’s joint motion to dismiss under Federal Rules of Civil Procedure 12(b)(5), (6) and (7). Filing 8. Douglas County also moves to strike Carroll’s demand for a jury trial and for an order directing Carroll to join Wellpath as a defendant. Filing 8. For the reasons stated herein, the Court denies Douglas County’s motion to dismiss, grants Myers’s motion to dismiss, grants Douglas County’s motion to strike, and orders Carroll to join Wellpath as a defendant. II. BACKGROUND This case involves the alleged beating of Carroll by several Douglas County corrections officers while Carroll was a pre-trial detainee at the Douglas County Department of Corrections, which Carroll refers to as the Douglas County Jail. Filing 1 at 1. On October 18, 2020, Carroll was arrested and detained at the Douglas County Jail. Filing 1 at 3. While in the waiting cell dressing

room, a corrections officer denied Carroll’s request for a phone call. Filing 1 at 4. Carroll also alleges that two corrections officers threatened to beat Carroll after handcuffing him. Filing 1 at 4. Carroll alleges one of the corrections officers pinched and squeezed Carroll’s triceps while escorting him towards the nurse’s room, causing him pain. Filing 1 at 4. Carroll told the corrections officer that the pinching hurt him and jerked away. Filing 1 at 4. Once Carroll jerked away, two of the corrections officers who were escorting him allegedly pushed him into a chair, causing his head to hit a concrete wall. Filing 1 at 4-5. Carroll contends multiple corrections officers then assaulted him, causing him physical injury. Filing 1 at 5. Carroll also claims a nurse at the nearby nurse’s station failed to intervene. Filing 1 at 5.

Despite Carroll needing medical attention, the corrections officers placed him in the suicide room jail cell for several hours before he was finally transported to the hospital. Filing 1 at 6. His medical care included wiring the bridge of his mouth to hold his teeth in place. Filing 1 at 6. According to Carroll, the corrections officers and nurse tried to cover up the incident resulting in Carroll’s injuries. Filing 1 at 6. He alleges that the corrections officers placed him in the suicide room jail cell so others could not see his injuries, Filing 1 at 7, and that they entered false information into logbooks to make it appear that Carroll assaulted an officer and was suicidal. Filing 1 at 6. Carroll also claims that the Chief Corrections Officer, under the guise of being an attorney, called Carroll to ask him about assaulting one of the corrections officers. Filing 1 at 7. Carroll denied having assaulted anyone at the jail and asked to check the jail’s video cameras. Filing 1 at 7. Ultimately, Carroll alleges that Douglas County Jail’s internal affairs did not investigate his beating nor discipline the corrections officers involved. Filing 1 at 7. On June 17, 2021, Carroll sued Douglas County, Michael Myers, the corrections officers that injured him, and the nurse that failed to intervene or provide medical care pursuant to 42

U.S.C. § 1983 for violating his Fourth, Sixth, and Fourteenth Amendment rights. Filing 1. In his allegations against Douglas County, Carroll claims Douglas County has an “institutional practice or custom, constituting an official policy” of covering up misconduct, such as excessive force, by Douglas County corrections officers and allowing corrections officers to prevent detainees from using the phone. Filing 1 at 8. He also asserts that Douglas County fails to supervise or train their employees. Filing 1 at 8. More specifically, Carroll claims that Douglas County fails to train employees on proper investigative procedures, allows corrections officers to continue working while being investigated for serious misconduct, fails to incentivize reporting misconduct while protecting those who cover up misconduct, and creates an atmosphere that discourages treating

injuries to detainees. Filing 1 at 8-9. Douglas County filed its Motion to Dismiss under Federal Rules of Civil Procedure 12(b)(5), (6) and (7) on July 13, 2021. Filing 8. III. ANALYSIS A. Failure to State a Monell Claim First, Douglas County moves to dismiss Carroll’s Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) on the basis that Carroll failed to plead a valid claim under which it, as a municipal entity, could be held liable pursuant to 42 U.S.C. § 1983. Filing 10 at 1. Specifically, Douglas County asserts that Carroll’s “entire list of alleged policies and customs [purporting to show a violation] is conclusory” and that “the facts of his case alone are insufficient to suggest the existence of an unconstitutional policy or custom.” Filing 10 at 8, 10. Carroll responds that Douglas County’s argument ignores the fact that he “included ample factual allegations preceding the allegations that contained his conclusions.” Filing 13 at 2. He further contends that when his complaint is viewed “[i]n light of these specific factual allegations . . . the Court should find the Complaint sufficiently meets the plausibility standard.” Filing 13 at 10. The Court finds Carroll

has adequately stated a claim for municipal liability and Douglas County’s 12(b)(6) motion must be denied. 1. Applicable Law 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). In order to satisfy this requirement, a plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.” Corrado v. Life Inv’rs Ins. Co. of Am., 804 F.3d 915, 917 (8th Cir. 2015) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Barton v. Taber, 820 F.3d 958, 964 (8th Cir. 2016) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). In analyzing a motion to dismiss, the Court must “accept as true all factual allegations in the complaint and draw all reasonable inferences in favor of the nonmoving party, but [is] not bound to accept as true ‘[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements’ or legal conclusions couched as factual allegations.” McDonough v.

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Carroll v. Douglas County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carroll-v-douglas-county-ned-2021.