Crider v. Williams

CourtDistrict Court, N.D. Alabama
DecidedMarch 31, 2025
Docket2:20-cv-01518
StatusUnknown

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

Bluebook
Crider v. Williams, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION JANEMARIE CRIDER, et al., ) ) Plaintiffs, ) ) v. ) Case No. 2:20-cv-01518-SGC ) ANITA WILLIAMS, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER1 In their third amended complaint, the plaintiffs, Janemarie Crider and Tucker Anderson (collectively, “the Parents”), name Anita Williams as the sole defendant and assert three causes of action: (1) a violation of 42 U.S.C. § 1983, (2) malicious prosecution, and (3) abuse of process. (Doc. 54).2 The Parents have moved for partial summary judgment, and Williams has moved for summary judgment in full. (Docs. 103-107). The parties’ cross-motions are fully briefed and ripe for adjudication. (Docs. 108-111, 113, 121, 126). For the reasons stated below, the court will grant summary judgment in favor of Williams on the Parents’ state law claims for malicious prosecution and abuse of

1 The parties have unanimously consented to magistrate judge jurisdiction pursuant to 28 U.S.C. § 636(c). (Doc.20). 2 Citations to the record refer to the document and page numbers assigned by the court’s CM/ECF electronic document system and appear in the following format: (Doc. __ at __). process and will deny the Parents’ motion for partial summary judgment. Further, the Parents will be given an opportunity to address a fatal flaw with their § 1983

claim, identified by the court after a hearing in October 2024. See FED. R. CIV. P. 56(f). I. Standard of Review The standard of review for cross motions for summary judgment is the same

as when only one party files a motion for summary judgment. S. Pilot Ins. Co. v. CECS, Inc., 52 F. Supp. 3d 1240, 1242–43 (N.D. Ga. 2014) (citing Am. Bankers Ins. Grp. v. United States, 408 F.3d 1328, 1331 (11th Cir. 2005)). Under Rule 56 of the

Federal Rules of Civil Procedure, summary judgment is proper “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” Celotex Corp. v. Catrett,

477 U.S. 317, 322 (1986). The party asking for summary judgment always bears the initial responsibility of informing the court of the basis for its motion and identifying those portions of the pleadings or filings which it believes demonstrate the absence

of a genuine issue of material fact. Id. at 323. Once the moving party has met its burden, the non-moving party must go beyond the pleadings and by his own affidavits, or by the depositions, answers to interrogatories, and admissions on file, designate specific facts showing there is a genuine issue for trial. See id. at 324. The substantive law identifies which facts are material and which are irrelevant. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). Only

disputes over facts that might affect the outcome of the case will preclude summary judgment. Id. All reasonable doubts about the facts and all justifiable inferences are resolved in favor of the non-movant. See Fitzpatrick v. City of Atlanta, 2 F.3d 1112,

1115 (11th Cir. 1993). A dispute is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson, 477 U.S. at 248. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted. See id. at 249.

Where, as here, a federal district court has diversity jurisdiction over state law claims, the court must apply the substantive law of the forum state. See McMahan v. Toto, 256 F.3d 1120, 1132 (11th Cir. 2001) (citing Erie R. Co. v. Tompkins, 304 U.S.

64, 78 (1938)). Consequently, substantive Alabama law applies to the Parents’ malicious prosecution and abuse of process claims. II. Undisputed Facts A.C. (the “Child”) was born to the Parents on June 26, 2015, in Tennessee.

(Doc. 104-1 at 3). On the day the Child was discharged from the hospital, the Parents were arrested for possession of marijuana. (Doc. 107-4 at 17; Doc. 107-5 at 13). Anderson ultimately pleaded guilty, and the charges against Crider were dismissed. (Doc. 107-4 at 33-34; Doc. 107-5 at 13-14). At some point between August 2015 and March 2016, the Parents were present for an extended time in Blount County, Alabama; there is conflicting

evidence as to whether they moved there for a period of several months, were simply visiting for a few months, or were residing in both Alabama and Tennessee during this period. Regardless of the length of their stay and the reason for their presence in

Alabama, the Parents stayed in a dwelling provided for them by Anderson’s mother, Andrea Anderson (“Andrea”). (Doc. 104-1 at 17). The Parents allege that, at some point, Andrea told them she would use the Department of Human Resources to take the Child from them. (Id. at 15).

In March 2016, Williams worked as an investigator for the Blount County Department of Human Resources (“DHR”). (Doc. 107-3 at 2). On March 18, 2016, she went to the Parents’ home to investigate a report concerning the Parents and

Child. (Id.). When Anderson answered the door, Williams told him someone had reported the Parents were using marijuana and distributing it to neighborhood children and the Child was not receiving medical care. (Id.). Anderson told Williams the Parents had been in Alabama for 3-4 months, his wife was bedbound, he had not

had time to find a pediatrician, and he did not smoke marijuana. (Id.). Although Anderson did not allow Williams to enter the home, he did permit her to see the Child. (Id.). Williams thought the Child appeared to be healthy. (Id.). Anderson and Williams made an appointment for her to return a week later on March 23, 2016. (Id.).

The Parents traveled to Knoxville, Tennessee on March 23, 2016, the day of their follow-up appointment with Williams.3 (Doc. 104-1 at 15, 34). When Williams returned to the Parents’ home for the appointment, no one was home; instead, she

found a note stating: To whom it may concern, We have had personal issues arise & had to leave suddenly. Please leave your contact info & we will get back to you upon return. Thank you, God Bless (Doc. 107-3 at 53). Williams left her card. (Id. at 42, 53). She also spoke to a neighbor, who told her the family had lived in the house since the end of the prior year. (Doc. 104-2 at 23). On March 24, 2016, Williams received a phone call from Andrea. (Doc. 107- 3 at 3). Williams told Andrea she would not discuss the case but asked Andrea to

have the Parents contact Williams. (Id. at 12). On March 29, Andrea contacted Williams and told her: • Anderson had Asperger syndrome; • Crider had mental health issues;

• the Parents frequently fought;

3 In their brief, the Parents assert this was because of Andrea’s comments to them, but the testimony they cite does not directly support that contention.

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Crider v. Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crider-v-williams-alnd-2025.