Causey v. Henderson Police Department

District Court, D. Nevada·Decided March 21, 2023·No. 2:23-cv-00421·Unknown

Opinion

* * *

WENDELL KEITH CAUSEY, Case No. 2:23-cv-00421-RFB-EJY

Plaintiff, ORDER and v. REPORT AND RECOMMENDATION

HENDERSON POLICE DEPARTMENT, et Re: ECF No. 1-1 al., Plaintiff’s Complaint Defendants. This matter is before the Court for screening of Plaintiff’s application to proceed in forma pauperis (“IFP”) and Complaint. ECF Nos.1, 1-1. Plaintiff’s IFP is complete and demonstrates an inability to pay filing fees. Thus, the Court grants Plaintiff’s IFP status. Upon granting a request to proceed in forma pauperis, a court must screen the complaint under 28 U.S.C. § 1915(e)(2). In its review, the court must identify any cognizable claims and dismiss any claims that are frivolous, 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. See 28 U.S.C. § 1915A(b)(1), (2). Pro se pleadings, however, must be liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: (1) the violation of a right secured by the Constitution or laws of the United States, and (2) that the alleged violation was committed by a person acting under color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). In addition to the screening requirements under § 1915A, pursuant to the Prison Litigation Reform Act, a federal court must dismiss a prisoner’s claim, if “the allegation of poverty is untrue,” or if the action “is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2). Dismissal of a complaint for failure to state a claim upon which relief can be granted is provided for when reviewing the adequacy of a complaint or an amended complaint. When a court dismisses a complaint under § 1915(e), the plaintiff should be given leave to amend the complaint with directions as to curing its deficiencies, unless it is clear from the face of the complaint that the deficiencies could not be cured by amendment. Cato v. United States, 70 F.3d 1103, 1106 (9th Cir. 1995). Review under Rule 12(b)(6) is essentially a ruling on a question of law. Chappel v. Lab. Corp. of America, 232 F.3d 719, 723 (9th Cir. 2000). Dismissal for failure to state a claim is proper only if it is clear that the plaintiff cannot prove any set of facts in support of the claim that would entitle him or her to relief. Morley v. Walker, 175 F.3d 756, 759 (9th Cir. 1999). In making this determination, the court takes as true all allegations of material fact stated in the complaint, and the court construes them in the light most favorable to the plaintiff. Warshaw v. Xoma Corp., 74 F.3d 955, 957 (9th Cir. 1996). Allegations of a pro se complainant are held to less stringent standards than formal pleadings drafted by lawyers. Hughes v. Rowe, 449 U.S. 5, 9 (1980). While the standard under Rule 12(b)(6) does not require detailed factual allegations, a plaintiff must provide more than mere labels and conclusions. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). A formulaic recitation of the elements of a cause of action is insufficient. Id. Additionally, a reviewing court should “begin by identifying pleadings [allegations] that, because they are no more than [mere] conclusions, are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). “While legal conclusions can provide the framework of a complaint, they must be supported with factual allegations.” Id. “When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. “Determining whether a complaint states a plausible claim for relief … [is] a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. Finally, all or part of a complaint filed by a prisoner may therefore be dismissed sua sponte if the prisoner’s claims lack an arguable basis either in law or in fact. This includes claims based on legal conclusions that are untenable (e.g., claims against defendants who are immune from suit or claims of infringement of a legal interest which clearly does not exist), as well as claims based on fanciful factual allegations (e.g., fantastic or delusional scenarios). Neitzke v. Williams, 490 U.S. 319, 327-28 (1989); see also McKeever v. Block, 932 F.2d 795, 798 (9th Cir. 1991). Plaintiff’s Complaint offers a slim set of facts suggesting a judge ordered Plaintiff to change into an orange jumpsuit, which included taking off a belt. ECF No. 1-1 at 4. This appears to have led to a jail guard alleging Plaintiff almost hit him followed by the jailer breaking Plaintiff’s rib. Id. Plaintiff sues the Henderson Police Department (“HPD”) alleging excessive force. Id. at 3. To state a claim under 42 U.S.C. § 1983 against the HPD, Plaintiff must allege a constitutional violation arising out of an official department policy, practice, or custom. Monell v. Department of Social Services of N.Y., 436 U.S. 658, 690 (1978); Tsao v. Desert Palace, Inc., 698 F.3d 1128, 1138-39 (9th Cir. 2012); Clouthier v. County of Contra Costa, 591 F.3d 1232, 1249 (9th Cir. 2010). “First, a local government may be held liable ‘when implementation of its official policies or established customs inflicts the constitutional injury.’” Clouthier, 591 F.3d at 1249 (quoting Monell, 436 U.S. at 708 (Powell, J. concurring)). “Second, under certain circumstances, a local government may be held liable under § 1983 for acts of omission, when such omissions amount to the local government’s own official policy.” Id. “Third, a local government may be held liable under § 1983 when ‘the individual who committed the constitutional tort was an official with final policy-making authority’ or such an official ‘ratified a subordinate’s unconstitutional decision or action and the basis for it.’” Id. at 1250 (quoting Gillette v. Delmore, 979 F.2d 1342, 1346-47 (9th Cir. 1992)). A single act by a non-policymaking official does not show the existence of a policy, custom, or practice. Rivera v. County of Los Angeles, 745 F.3d 384, 389 (9th Cir. 2014). A municipal defendant may not be sued solely because an injury was inflicted by one of its e

Free access — add to your briefcase to read the full text and ask questions with AI

Causey v. Henderson Police Department, (D. Nev. 2023).

Causey v. Henderson Police Department (Causey v. Henderson Police Department) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Hughes v. Rowe
449 U.S. 5 (Supreme Court, 1980)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Carvell
74 F.3d 8 (First Circuit, 1996)
Edward McKeever Jr. v. Sherman Block
932 F.2d 795 (Ninth Circuit, 1991)
James Gillette v. Duane Delmore, and City of Eugene
979 F.2d 1342 (Ninth Circuit, 1992)
Clouthier v. County of Contra Costa
591 F.3d 1232 (Ninth Circuit, 2010)
Wilkins v. Ramirez
455 F. Supp. 2d 1080 (S.D. California, 2006)
Santiago Rivera v. County of Los Angeles
745 F.3d 384 (Ninth Circuit, 2014)