Clark v. Board of County Commissioners

CourtDistrict Court, W.D. Oklahoma
DecidedSeptember 30, 2025
Docket5:24-cv-01241
StatusUnknown

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

Bluebook
Clark v. Board of County Commissioners, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA JENNIFER CLARK, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-1241-SLP ) (District Court of Canadian CANADIAN COUNTY ex rel. ) County, Case No. CJ-2024-328) THE BOARD OF COUNTY ) COMMISSIONERS, et al., ) ) Defendants. ) O R D E R Before the Court is the Motion to Dismiss [Doc. No. 12] filed by Defendants Board of County Commissioners of Canadian County, Oklahoma (Canadian County BOCC) and Sheriff Chris West, individually and in his official capacity as Sheriff of Canadian County. Plaintiff Jennifer Clark has responded [Doc. No. 28], and Defendants have replied [Doc. No. 32]. Also before the Court is Defendant David Loman’s Motion to Dismiss [Doc. No. 13], to which Ms. Clark has responded [Doc. No. 29] and Mr. Loman has replied [Doc. No. 33]. Accordingly, both matters are fully briefed and ready for determination. I. Introduction Ms. Clark brings this action based on an alleged sexual assault by Mr. Loman, a former Sheriff’s Deputy, while transporting her to the Canadian County Jail on August 31, 2021. See generally Am. Compl. [Doc. No. 11]. Ms. Clark filed this action in the District Court of Canadian County, State of Oklahoma, but it was removed to this Court on November 27, 2024. See Corrected Pet. [Doc. No. 1-7]; see also Notice of Removal [Doc. No. 1]. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 because Ms. Clark brings claims pursuant to federal law: 42 U.S.C. § 1983 and 18 U.S.C. § 1591(a). Ms. Clark names Sheriff West and Mr. Loman in their official and individual

capacities. Am. Compl. [Doc. No. 11] at 1. She brings § 1983 claims against Mr. Loman for “Excessive Force/Bodily Integrity” and substantive due process under the Fourteenth Amendment.1 Id. at 30-34. She asserts claims against both Mr. Loman and Sheriff West for violation of equal protection, violation of the Trafficking Victims Protection Reauthorization Act (TVPRA), 18 U.S.C. § 1591, and sexual assault and battery under

Oklahoma criminal statutes, 21 Okla. Stat. §§ 888, 1029, 1111, and 1123. Id. at 35-46. Ms. Clark also brings a claim for supervisory liability against Sheriff West, and a municipal liability claim against Sheriff West and Canadian County BOCC. Id. at 38-42.2 Sheriff West and Canadian County BOCC move for dismissal pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). They contend Ms. Clark’s § 1983 claims

are barred by the applicable statute of limitations and qualified immunity, and that the claims against Canadian County BOCC are redundant to those against Sheriff West in his official capacity. See Mot. [Doc No. 12] at 7-17. They further contend the Court lacks jurisdiction over the state law claims because Ms. Clark failed to comply with the notice requirements of the Oklahoma Governmental Tort Claims Act (GTCA). Id. at 18-19.

1 Ms. Clark states that she brings her claim against Mr. Loman under the Eighth and Fourteenth Amendments alternatively because there is a split in authority on whether a person detained on probation violations is considered a pretrial detainee triggering Fourteenth Amendment analysis or a convicted inmate triggering Eighth Amendment analysis. Id. ¶ 215.

2 Ms. Clark does not identify which claims are brought against Sheriff West and/or Mr. Loman in their individual capacities versus their official capacities. See id. Sheriff West alternatively asserts that the state law claims against him in his official capacity are barred by sovereign immunity, and Ms. Clark fails to state a plausible claim against him in his individual capacity. Id. at 20-28. Finally, they argue that Ms. Clark has

failed to state a claim for violation of the TVPRA. Id. at 28-31. Mr. Loman likewise moves for dismissal of all claims asserted against him. See Mot. [Doc. No. 13]. He similarly asserts that Ms. Clark’s § 1983 claims are time-barred and that she fails to plausibly allege a violation of the TVPRA. Id. at 4-6. He further asserts that Ms. Clark’s claim for assault and battery under Oklahoma criminal statutes is

time-barred. Id. at 6. II. Governing Standard To withstand a motion to dismiss under Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550

U.S. 544, 570 (2007)). A facially plausible complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” S.E.C. v. Shields, 744 F.3d 633, 640 (10th Cir. 2014) (quoting Iqbal, 556 U.S. at 678). While the complaint need not contain “detailed factual allegations,” it must include “more than labels and conclusions” or a “formulaic recitation of the elements of a cause of

action” to avoid dismissal. Twombly, 550 U.S. at 555. The Court views the allegations in the light most favorable to the non-moving party and draws all reasonable inferences in the non-moving party’s favor. Brown v. City of Tulsa, 124 F.4th 1251, 1263 (10th Cir. 2025). Motions to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1) constitute either “(1) a facial attack on the sufficiency of the complaint’s allegations as to subject matter jurisdiction; or (2) a challenge to the actual facts upon which subject matter

jurisdiction is based.” Ruiz v. McDonnell, 299 F.3d 1173, 1180 (10th Cir. 2002). Where, as here, the motion is a facial attack, the Court applies “a standard patterned on Rule 12(b)(6) and assume[s] the truthfulness of the facts alleged.” Utah Native Plant Soc'y v. United States Forest Serv., 923 F.3d 860, 865 (10th Cir. 2019) (internal quotations and citations omitted).

III. Factual Allegations of the Complaint Ms. Clark’s Amended Complaint3 [Doc. No. 11] includes 311 numbered paragraphs and spans forty-eight pages without exhibits. See id. The Court only summarizes the facts alleged, and it further discusses facts relevant to the legal issues presented below. On March 11, 2020, Ms. Clark pled guilty to a drug trafficking charge in Case No.

CF-2019-614 in Canadian County, Oklahoma. Am. Compl. [Doc. No. 11] ¶¶ 57-58. She received a seven-year suspended sentence except for an initial 114 days in the Canadian County Jail. Id. ¶ 58. On January 6, 2021, the Canadian County District Attorney filed an application to revoke Ms. Clark’s suspended sentence, and a bench warrant for her arrest was issued the same date. Id. ¶ 60. The warrant was returned on February 25, 2021, and

Ms. Clark posted bond on March 3, 2021. Id. ¶ 61.

3 Although titled “First Amended Petition” the Court uses the nomenclature applicable in federal court. Another bench warrant was issued as to Ms. Clark on March 8, 2021 based on a failure to appear on February 16, 2021. Id. ¶ 62. Pursuant to that warrant, Ms. Clark was arrested in Pottawatomie County on August 26, 2021. See id. ¶ 63. On August 31, 2021,

either at the direction of Sheriff West or by volunteering, Mr. Loman went to Pottawatomie County to transfer Ms. Clark to the Canadian County Jail. Id. ¶¶ 69-70. Mr. Loman picked up Ms. Clark the same day. See id. ¶ 80. He was not accompanied by any other officer, and he did not have a body or dash camera.4 Id. ¶¶ 70- 71. Mr.

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