Chen v. Lansing, City of

CourtDistrict Court, W.D. Michigan
DecidedAugust 6, 2021
Docket1:19-cv-00651
StatusUnknown

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

Bluebook
Chen v. Lansing, City of, (W.D. Mich. 2021).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

LE CHEN, ) Plaintiff, ) ) No. 1:19-cv-651 -v- ) ) Honorable Paul L. Maloney CITY OF LANSING, ., ) Defendants. ) )

ORDER ADOPTING REPORT AND RECOMMENDATION

Plaintiff Le Chen, proceeding without the benefit of counsel, filed a civil rights action against the City of Lansing, the Lansing Police Department, and two police officers. After Plaintiff filed a second amended complaint (ECF No. 31 Compl.), Defendants filed a motion to dismiss (ECF No. 37). The Court referred the motion to the Magistrate Judge, who issued a report recommending that the Court grant Defendants’ motion. (ECF No. 42.) Plaintiff filed objections. (ECF No. 45.) After being served with a report and recommendation (R&R) issued by a magistrate judge, a party has fourteen days to file written objections to the proposed findings and recommendations. 28 U.S.C. § 636(b)(1); Fed. R. Civ. P. 72(b)(2). A district court judge reviews de novo the portions of the R&R to which objections have been filed. 28 U.S.C. § 636(b)(1); Fed. R. Civ. P. 72(b)(3). Only those objections that are specific are entitled to a de novo review under the statute. , 806 F.2d 636, 637 (6th Cir. 1986) (per curiam). A. False Arrest and Tolling The Magistrate Judge concludes that Plaintiff’s false arrest claim accrued on June 12, 2016, the day he was arrested and arraigned. Plaintiff filed this lawsuit in August 2019.

Applying Michigan’s three-year statute of limitation, the Magistrate Judge concludes that Plaintiff’s false arrest claim is untimely. Plaintiff objects. The Court overrules Plaintiff’s objections concerning the false arrest claim. Plaintiff was arrested, arraigned, and released on bond on June 12, 2016. (Compl. ¶¶ 20-24 PageID.254-55.) His false arrest claim accrued on that day. ,

549 U.S. 384, 397 (2007); , 984 F.3d 1156, 1161-63 (6th Cir. 2021). The Court has carefully considered Plaintiff’s objections, including his discussion of and , 512 U.S. 477 (1994) and his discussion of and , and finds no error in the findings and recommendations in the report and recommendation. Plaintiff does assert that his false arrest claim against the municipal defendants did not

accrue until May 2018, when he received the Internal Review Report and letter. ( Compl. ¶¶ 28-29 PageID.256.) Plaintiff reasons he was not aware that his arrest was conducted in a manner consistent with established policies and procedures until May 9, 2018. This argument would not affect the conclusion that Plaintiff’s false arrest claim against the individual defendants accrued in June 2016. Plaintiff does not plead that his arrest was the

result of an municipal policy, practice or custom. Plaintiff does not describe, in any detail, what the policy or procedure was or why the policy failed. Merely reciting the elements of a claim and relying on unsubstantiated inferences that the policy and procedure must have been deficient fails to plead the facts necessary to state a claim. And, as the Magistrate Judge concludes, the false arrest claim arises from the lack of probable cause, not compliance with a municipality’s customs, policies and procedures.

Plaintiff contends that he has diligently pursued his rights, but extraordinary circumstances prevented him from timely filing the complaint. The Court is not persuaded. The party seeking equitable tolling bears the burden of showing both that he or she acted diligently and that extraordinary circumstances stood in the way. , 544 U.S. 408, 418 (2005). Plaintiff has not established that any extraordinary circumstances

prevented him from filing this lawsuit before the statute of limitation expired. Plaintiff has repeatedly argued that he suffered from post-traumatic stress disorder (PTSD), depression and other conditions as a result of his arrest. Mere allegations of a medical condition, and even a medical diagnosis, by itself, does not establish a basis for equitable tolling. The moving party must prove that the condition prevented the party from deliberate decision making or rational thought and thus rendered the party unable to handle his or her own

affairs. , 363 F.3d 1316, 1321 (Fed. Cir. 2004); , 662 F.3d 736, 741-42 (6th Cir. 2011) (holding that a moving party must show not only the existence of mental condition, but also how that condition caused the failure to meet the filing deadline and explaining that “a blanket assertion of mental incompetence is insufficient to toll the statute of limitations.”). Plaintiff admits that he was sufficiently capable of pursuing some

remedies because he filed a citizen complaint against one of the individual officers in 2018. B. Malicious Prosecution The Magistrate Judge concludes that Plaintiff failed to plead facts to support the first element for a malicious prosecution claim. The Magistrate Judge finds that Plaintiff was not

prosecuted by any named defendant and the allegations in the complaint do not show that any defendant influenced the decision to prosecute. Plaintiff objects. The Court overrules Plaintiff’s objection on the malicious prosecution claim. Plaintiff insists that the individual defendants intentionally hid exculpatory evidence. Plaintiff also argues that Defendants fabricated probable cause by intentionally making false

statements and coaching witnesses by asking misleading questions. Plaintiff’s complaint, however, does not contain any of these allegations.1 Plaintiff pleads that Bierer made a false police report; he does not plead Defendants made false statements. (Compl. ¶ 20 PageID.254.) At best, Plaintiff perfunctorily pleads that Defendants fabricated evidence and stated deliberate falsehoods. ( ¶ 44 PageID.258.) This particular allegation is utterly devoid of any detail. Such naked assertions need not be accepted as true for the purpose of

a Rule 12 motions. 774 F.3d 351, 355 (6th Cir. 2014). C. Unlawful Seizure Plaintiff’s unlawful seizure claim arises from the conditions imposed as terms of his bond. The Magistrate Judge concludes that Plaintiff has not pled facts to show that

1 Here, and elsewhere in his objections, Plaintiff references the police report. The police report is not part of the record. The contents of the police report are not included in the complaint. Defendants were responsible for the alleged seizure. Plaintiff objects. The Court overrules Plaintiff’s objection on the unlawful seizure claim. Plaintiff’s objection for this claim functionally repeats the arguments he makes to

support his malicious prosecution claims. Plaintiff reasons that but for his unlawful arrest and Defendant’s fabrication of evidence, he would not have been “seized” when the conditions of bond were set. The Court has concluded that Plaintiff did not sufficiently plead fabrication of evidence or false statements by Defendants. D. Fabrication of Evidence

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

Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Rondigo, L.L.C. v. Township of Richmond
641 F.3d 673 (Sixth Circuit, 2011)
Keith A. Mira v. Ronald C. Marshall
806 F.2d 636 (Sixth Circuit, 1986)
ATA v. Scutt
662 F.3d 736 (Sixth Circuit, 2011)
SFS Check, LLC v. First Bank of Delaware
774 F.3d 351 (Sixth Circuit, 2014)
Calvin Dibrell v. City of Knoxville, Tenn.
984 F.3d 1156 (Sixth Circuit, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Chen v. Lansing, City of, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chen-v-lansing-city-of-miwd-2021.