Davis v. Dollar General Corporation

CourtDistrict Court, E.D. Arkansas
DecidedSeptember 29, 2022
Docket4:21-cv-00470
StatusUnknown

This text of Davis v. Dollar General Corporation (Davis v. Dollar General Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davis v. Dollar General Corporation, (E.D. Ark. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION CHARLES DAVIS, et al. PLAINTIFFS v. CASE NO. 4:21-CV-00470-BSM DOLLAR GENERAL CORPORATION, et al. DEFENDANTS ORDER Marty Boyd’s unopposed motion to dismiss [Doc. No. 4] is granted; William J. Bryant

and Tanner Middlecoff’s motion to dismiss [Doc. No. 7] is granted; and Rick Elliott’s motion to dismiss [Doc. No. 30] is granted. Dollar General Corporation’s motion to dismiss [Doc. No. 12] is denied on the negligence, intentional infliction of emotional distress, and wrongful death claims, and granted on all other claims. Bryant and Middlecoff’s motion to

strike [Doc. No. 21] is denied, and plaintiffs’ motion to accept their out of time response [Doc. No. 22] is granted. Bryant, Middlecoff, and Elliott’s motions to stay discovery [Doc. Nos. 17, 29, 32] are denied as moot. I. BACKGROUND Plaintiffs are suing defendants for allegedly negligent, reckless, and malicious actions

that caused the death of Lakita Davis and injured Octavia Jackson. Plaintiffs allege that employees of Dollar General Corporation lied to law enforcement when they reported that Davis robbed the store. Compl. ¶¶ 16–17, Doc. No. 1. This lie was perpetrated in order to induce an “accelerated response” to what, at most, could be characterized as shoplifting. Id.

Upon receiving the call, Arkansas State Trooper Tanner Middlecoff engaged in a vehicle chase with the car driven by Davis and in which Jackson was a passenger. Id. ¶¶18–19. During the chase, Middlecoff performed a maneuver that violated State Police policy,

causing Davis’s car to flip over. Id. ¶¶ 22–23. Plaintiffs are suing Dollar General Corporation; Rick Elliott, individually and in his officially capacity as Chief of the Jonesboro Police Department; Marty Boyd, individually and in his official capacity as Craighead County Sheriff; William J. Bryant, individually and in his official capacity as Director of the Arkansas State Police; and Tanner Middlecoff,

individually and in his official capacity as an Arkansas State Police Officer. Plaintiffs allege wrongful death, violations of 42 U.S.C. section 1983, negligence, intentional infliction of emotional distress, loss of consortium, and negligent infliction of emotional distress. II. LEGAL STANDARD

Federal Rule of Civil Procedure 12(b)(6) permits dismissal when a plaintiff fails to state a claim upon which relief may be granted. To overcome a 12(b)(6) motion, the complaint must allege sufficient facts to entitle the plaintiff to the relief sought. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007).

Although detailed factual allegations are not required, threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, are insufficient. Ashcroft, 556 U.S. at 678. All well pleaded allegations in the complaint are accepted as true and construed in the light most favorable to the plaintiff. Id. III. DISCUSSION

2 A. Claims against the Law Enforcement Officers The motions to dismiss the claims against Elliott, Boyd, Bryant, and Middlecoff are

granted. 1. Section 1983 Individual Capacity Claims The 42 U.S.C. section 1983 individual capacity claims against the law enforcement officers are dismissed because the officers are immune from suit. See Pearson v. Callahan, 555 U.S. 223, 244 (2009) (law enforcement officers have qualified immunity when they

reasonably believe their conduct complies with the law). This is true because government officials are immune from suit unless they violate clearly established rights. Id. at 231. Immunity attaches even when an official makes a mistake of law or fact. Id. Therefore, when determining whether an official is immune, courts consider (1) whether the allegations

establish a violation of a constitutional right, and (2) whether that right was clearly established at the time of the alleged violation, such that a reasonable officer would have known that his actions were unlawful. Id. at 232. If either question is answered in the negative, then the official is entitled to qualified immunity. Id. at 236.

Whether Elliott, Boyd, and Bryant are immune is an easier call than whether Middlecoff is immune. This is true because the complaint states no facts against Bryant and the only allegations against Elliott and Boyd are that they “gave chase” to plaintiffs, and that they failed to train their officers on how to coordinate a police chase with other agencies.

3 Compl. ¶ 21. These allegations are not sufficient to allege they violated clearly established statutory or constitutional rights. Plaintiffs allege that Middlecoff violated the constitutional rights of Lakita Davis and

Jackson when he executed a pit maneuver in violation of Arkansas State Police policy while Davis was attempting to find a safe place to pull over. Compl. ¶ 22. Policy violations, however, do not automatically rise to the level of a constitutional violation, Kennedy v. Blankenship, 100 F.3d 640, 643 (8th Cir. 1996), and the Eighth Circuit has held that denying

an Arkansas State Police Officer qualified immunity because he performed a pit maneuver is reversible error. Moore-Jones v. Quick, 909 F.3d 983, 985–87 (8th Cir. 2018). Importantly, the Eighth Circuit held that a trooper was justified in using force to secure compliance, because “from a reasonable officer’s perspective, [the driver] refused to comply with commands to pull over.” Id. As in Moore-Jones, Davis failed to pull over even though

she was aware that Middlecoff was attempting to stop her. Although the complaint alleges that Davis did not pull over because she feared for her life “based on previous history of police conduct,” Compl. ¶ 20, qualified immunity cannot be denied based upon Davis’s subjective thoughts. This is true because “[l]aw enforcement officers are not required to read

a suspect’s motivations in failing to obey commands–it is enough that the officer reasonably perceives that the suspect is not following orders as given.” Moore-Jones, 909 F.3d at 986 (citing Neal v. Ficcadenti, 895 F.3d 576, 581 (8th Cir. 2018)). 2. Section 1983 Official Capacity Claims

4 Plaintiffs’ official capacity claims against Elliott and Boyd are dismissed because they are essentially claims against the City of Jonesboro and Craighead County. Monell v. Dep’t Soc. Servs., 436 U.S. 658, 690 (1978). To bring a claim against the city or county, plaintiffs

must show that Elliott and Boyd violated Davis’s and Jackson’s rights pursuant to an official policy or unofficial custom of the city or county or that they failed to train or supervise the officers who violated the rights of Davis and Jackson. Corwin v. City of Independence, Mo., 829 F.3d 695, 699 (8th Cir. 2016). Plaintiffs have failed to meet this burden because they

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Davis v. Dollar General Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-v-dollar-general-corporation-ared-2022.