Cottman v. Rodriguez

CourtDistrict Court, D. South Carolina
DecidedSeptember 23, 2025
Docket2:23-cv-03104
StatusUnknown

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

Bluebook
Cottman v. Rodriguez, (D.S.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION Howard Cottman, Jr., Case No. 2:23-cv-03104-RMG

Plaintiff, v. ORDER Derek A. Rodriguez, Chirstopher Smith, McPherson, Royer, J.E. Roberts, and Sgt. Danielle Sherwood,

Defendants.

Before the Court is the Report and Recommendation (“R&R”) of the Magistrate Judge (Dkt. No. 108), recommending that Defendants’ motion for summary judgment (Dkt. No. 95) be granted and that Plaintiff’s motion to strike (Dkt. No. 106) Defendants’ reply (Dkt. No. 105) to Plaintiff’s response, opposing the motion for summary judgment (Dkt. No. 104), be denied. No objections to the R&R were filed by any party. For the reasons set forth below, the Court adopts the R&R as the Order of the Court, grants Defendants’ motion for summary judgment, and denies Plaintiff’s motion to strike Defendants’ reply. I. Background This action arises out of Plaintiff’s arrest on April 3, 2023. (Dkt. No. 57, at 9). Plaintiff alleges that while he was inside the apartment he purportedly shared with his common law wife, L.L., Defendants, employees of North Charleston Police Department, unlawfully entered the 1 apartment and arrested him without probable cause.1 Id. at 9-13. Plaintiff brings claims against Defendants in their individual and official capacities under 42 U.S.C. § 1983, alleging unlawful entry and malicious prosecution in violation of the Fourth Amendment to the United States Constitution. Id. Plaintiff also alleges that Defendants violated state law. Id. at 7. Defendants filed

a motion for summary judgment. (Dkt. No. 95). Plaintiff responded (Dkt. No. 104) and filed a motion to strike (Dkt. No. 106) Defendants’ reply (Dkt. No. 105) to Plaintiff’s response. On July 7, 2025, Plaintiff filed a motion for an extension of time to file objections to the R&R. (Dkt. No. 111). The Court granted the motion and extended the objection deadline to August 10, 2025. (Dkt. No. 113). On July 21, 2025, Plaintiff filed a Notice of Change of Address. (Dkt. No. 115). When no objections were received by the August 10 deadline, the Court—out of an abundance of caution—re-sent the R&R to Plaintiff’s updated address and sua sponte extended the deadline to September 18, 2025. (Dkt. No. 116). The motions at issue are ripe for disposition. II. Legal Standard A. Magistrate’s Report and Recommendation The Magistrate Judge makes only a recommendation to this Court. The recommendation

has no presumptive weight, and the responsibility for making a final determination remains with this Court. See Mathews v. Weber, 423 U.S. 261, 270–71 (1976). This Court is charged with making a de novo determination of those portions of the R&R to which specific objections are

1 Plaintiff was officially charged with first-degree domestic violence and violating a restraining order. (Dkt. No. 95-8, at 2-5). The charges were later dismissed as part of a plea deal. (Dkt. No. 95-9, at 3-4). 2 made. 28 U.S.C. § 636(b)(1). Additionally, the Court may “accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” Id. Where the plaintiff fails to file any specific objections, “a district court need not conduct a de novo review, but instead must only satisfy itself that there is no clear error on the face of the record in order to accept the

recommendation.” See Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005) (citation and punctuation omitted). B. Pro Se Pleadings This Court liberally construes complaints filed by pro se litigants to allow the development of a potentially meritorious case. See Cruz v. Beto, 405 U.S. 319, 322 (1972); Haines v. Kerner, 404 U.S. 519, 520-21 (1972). The requirement of liberal construction does not mean that the Court can ignore a clear failure in the pleadings to allege facts which set forth a viable federal claim, nor can the Court assume the existence of a genuine issue of material fact where none exists. See Weller v. Dep’t of Soc. Servs., 901 F.2d 387, 391 (4th Cir. 1990). C. Summary Judgment Summary judgment is appropriate if a party “shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).

A dispute is “genuine” if the evidence offered is such that a reasonable jury might return a verdict for the non-movant. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A fact is “material” if proof of its existence or non-existence would affect disposition of the case under applicable law. See id. Therefore, summary judgment should be granted “only when it is clear that there is no dispute concerning either the facts of the controversy or the inferences to be drawn from those facts.” Pulliam Inv. Co. v. Cameo Props., 810 F.2d 1282, 1286 (4th Cir. 1987) (citation omitted). 3 “In determining whether a genuine issue has been raised, the court must construe all inferences and ambiguities in favor of the nonmoving party.” HealthSouth Rehab. Hosp. v. Am. Nat’l Red Cross, 101 F.3d 1005, 1008 (4th Cir. 1996) (citation omitted). The movant bears the initial burden of demonstrating that there is no genuine issue of material fact. See Celotex Corp. v.

Catrett, 477 U.S. 317, 323 (1986). Once the moving party has made this threshold demonstration, the non-moving party, to survive the motion for summary judgment, must demonstrate that specific, material facts exist that give rise to a genuine issue. See id. at 324. Under this standard, “[c]onclusory or speculative allegations do not suffice, nor does a ‘mere scintilla of evidence’” in support of the non-moving party’s case. Thompson v. Potomac Elec. Power Co., 312 F.3d 645, 649 (4th Cir. 2002) (quoting Phillips v. CSX Transp., Inc., 190 F.3d 285, 287 (4th Cir. 1999)). III. Discussion The Court has reviewed the R&R, applicable caselaw, and the record evidence in this matter. The Court finds that the Magistrate Judge ably addressed the factual and legal issues in this matter and correctly concluded that Defendants’ motion for summary judgment should be granted and Plaintiff’s motion to strike Defendants’ reply should be denied. A. Individual Capacity Claims

The Magistrate Judge correctly concluded that Plaintiff’s § 1983 claim for unlawful entry against Defendants Roberts and Sherwood should be dismissed because Plaintiff has failed to allege facts showing that these Defendants were involved in the entry of the apartment and could not establish a basis for supervisory liability, bystander liability, or negligence under state law. As to the other Defendants, the Magistrate Judge correctly concluded that the record evidence showed that Plaintiff did not have a reasonable expectation of privacy in the apartment, and thus there was no violation of his Fourth Amendment rights when Defendants entered the apartment.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Cruz v. Beto
405 U.S. 319 (Supreme Court, 1972)
Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
George F. Thompson v. Potomac Electric Power Company
312 F.3d 645 (Fourth Circuit, 2002)
Phillips v. CSX Transportation, Inc.
190 F.3d 285 (Fourth Circuit, 1999)

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Cottman v. Rodriguez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cottman-v-rodriguez-scd-2025.