Craig v. Bullitt County, Kentucky

District Court, W.D. Kentucky·Decided October 4, 2024·No. 3:24-cv-00196·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE

HOLDEN ANTHONY CRAIG PLAINTIFF

v. CIVIL ACTION NO. 3:24CV-196-CRS

BULLITT COUNTY, KENTUCKY et al. DEFENDANTS

MEMORANDUM OPINION

Plaintiff Holden Anthony Craig filed the instant pro se action proceeding in forma pauperis. This matter is now before the Court on initial review of the amended complaint (DN 13)1 pursuant to 28 U.S.C. § 1915(e) and McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997), overruled on other grounds by Jones v. Bock, 549 U.S. 199 (2007). For the reasons that follow, the Court will dismiss the complaint without prejudice. I. SUMMARY OF ALLEGATIONS The complaint caption lists Bullitt County, Kentucky as the only Defendant. In the “Defendants” section of the complaint form, Plaintiff lists Kyle Bradshaw and Matt Roederer, who he identifies as police officers employed by the Shepherdsville Police Department. He does not indicate in what capacity he sues Defendant Bradshaw or Roederer. Plaintiff states that he “was on an excessive bail of $10,000.00.” He asserts, “It was cruel and unusual punishment because I was not permitted to leave the holding cell. This is solitary confinement. . . . Although I repeatedly denied being suicidal, I was on suicide watch for the entire duration of my wrongful imprisonment.” He continues, “I was woken up every fifteen minutes of every 24 hours, of the entire duration of my wrongful imprisonment. . . . I was forced to sleep on

1 By prior Memorandum and Order (DN 12), the Court directed Plaintiff to file an amended complaint on the Court’s approved form and stated that the amended complaint would supersede the original complaint. a concrete floor. . . [and] was forced to drink water from the sink in order to survive.” He asserts, “I was deprived of my medication, which is vital to keep me alive.” Plaintiff further states, “I lack substantially in mens rea. . . . I did not knowingly or intentionally escape from the hospital: Wellstone Regional Hospital.” He asserts, “I did not knowingly or intentionally resist arrest. . . . I did not resist arrest. . . . I did not break a body camera.

. . . I did not break a watch.” He maintains that “Maggie Troxell claims she saw the arresting officer turn off his body camera.” Plaintiff continues, “I was never given a reason as to why I was being detained. No probable cause. I asked, but never saw a warrant. I was never read my Miranda rights.” Plaintiff reports, “The E.D.O. that almost forced me into Wellstone Regional Hospital was ineffective because I signed myself in. In doing so, I did not evade the police by escaping.” He states, “Maggie Troxell has reason to believe that the arresting officer in the criminal paperwork is not the same officer who arrested me. . . I was assaulted by the police, they tried to break my arm.” He alleges, “I was discriminated against and wrongfully imprisoned because of my family

history & my sexuality. Entrapment.” As relief, he seeks compensatory damages and “expungement of records.” II. STANDARD Because Plaintiff is proceeding in forma pauperis, this Court must review the instant action. 28 U.S.C. § 1915(e); McGore, 114 F.3d at 608-09. Upon review, the Court must dismiss a case at any time if it determines that an action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915(e)(2)(B). This Court recognizes that pro se pleadings are to be held to a less stringent standard than formal pleadings drafted by lawyers. Haines v. Kerner, 404 2 U.S. 519 (1972); Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991). However, the duty “does not require us to conjure up unpled allegations.” McDonald v. Hall, 610 F.2d 16, 19 (1st Cir. 1979). In order to survive dismissal for failure to state a claim, “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) (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.” Id. (citing Twombly, 550 U.S. at 556). “[A] district court must (1) view the complaint in the light most favorable to the plaintiff and (2) take all well-pleaded factual allegations as true.” Tackett v. M & G Polymers, USA, LLC, 561 F.3d 478, 488 (6th Cir. 2009) (citing Gunasekera v. Irwin, 551 F.3d 461, 466 (6th Cir. 2009) (citations omitted)). “But the district court need not accept a ‘bare assertion of legal conclusions.’” Tackett, 561 F.3d at 488 (quoting Columbia Natural Res., Inc. v. Tatum, 58 F.3d 1101, 1109 (6th Cir. 1995)).

III. ANALYSIS A. Bullitt County and official-capacity claims Plaintiff does not indicate in which capacity he sues Defendant Bradshaw or Roederer. However, if had sued these Defendants in their official capacities, the claims would fail. “Official- capacity suits . . . ‘generally represent [] another way of pleading an action against an entity of which an officer is an agent.’” Kentucky v. Graham, 473 U.S. 159, 166 (1985) (quoting Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658, 691 n.55 (1978)). Therefore, Plaintiff’s official- capacity claims against Defendants are actually brought against their employer, the City of Shepherdsville. Id. at 165. 3 When a § 1983 claim is made against a municipality, such as the City of Shepherdsville or Bullitt County, this Court must analyze two distinct issues: (1) whether Plaintiff’s harm was caused by a constitutional violation; and (2) if so, whether the municipality is responsible for that violation. Collins v. City of Harker Heights, Tex., 503 U.S. 115, 120 (1992). In regard to the second component, a municipality cannot be held responsible for a constitutional deprivation

unless there is a direct causal link between a municipal policy or custom and the alleged constitutional deprivation. Monell, 436 U.S. at 691; Deaton v. Montgomery Cnty., Ohio, 989 F.2d 885, 889 (6th Cir. 1993). To demonstrate municipal liability, a plaintiff “must (1) identify the municipal policy or custom, (2) connect the policy to the municipality, and (3) show that his particular injury was incurred due to execution of that policy.” Alkire v. Irving, 330 F.3d 802, 815 (6th Cir.

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