Demurjian v. Dunbar

CourtDistrict Court, D. Maryland
DecidedFebruary 5, 2025
Docket1:23-cv-03180
StatusUnknown

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

Bluebook
Demurjian v. Dunbar, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT . - FOR THE DISTRICT OF MARYLAND

RICHARD DEMURJIAN, * . ‘Plaintiff, x . Vv. *, Civil No. 23-3180-BAH LEE DUNBAR ET AL., Defendants. * * * * * * * * * * * * * □ MEMORANDUM OPINION Plaintiff Richard Demurjian (‘‘Plaintiff’ or “Demurjian”) brought suit against (1) Lee . Dunbar (“Dunbar”), a. Major in the Harford County Sheriff's Office who runs the Recruit Academy, and (2)-the “Harford County Sheriff's Office-State of Maryland” (hereinafter “Sheriffs Office”) (collectively “Defendants”). See ECF 1 (complaint); ECF 22 (first amended complaint).'

. Specifically, Plaintiff brings a 42 U.S.C. § 1983 claim for unlawful search and seizure in violation of the Fourth and Fourteenth Amendments” against Dunbar in his individual capacity only (count

' Plaintiff had previously attempted to file the amended complaint at ECF 17. However, an erroneously issued (and later rescinded) quality control notice instructed Plaintiff to file a motion for leave to file an amended complaint. See ECF 18. Plaintiffs motion for leave, ECF 19, was granted, ECF 21. The first amended complaint at ECF 22 is the same document filed at ECF 17. . The Court will refer only to ECF 22 as the first amended complaint. 2 The Court assumes Plaintiff's citation to the Fourteenth Amendment to refer to the doctrine of incorporation, not as a standalone claim. See Mapp v. Ohio, 367 ULS. 643, 655 (1961) (explaining that the Fourteenth Amendment incorporated the Fourth Amendment as applicable to the states). Plaintiff's complaint makes clear that he only brings suit for unlawful search and seizure, not any due process violation, so the Court analyzes the claims under only the Fourth Amendment. See United States v. Lanier, 520 U.S. 259, 272 n.7 (1997) (“Graham . . . requires that ifa constitutional claim is covered by a specific constitutional provision, such as the Fourth or Eighth Amendment, the claim must be analyzed under the standard appropriate to that specific provision, not under the rubric of substantive due process.” (citing Graham v. Connor, 490 U.S. 386, 394 (1989))).

1) and a claim for age discrimination in violation of the Age Discrimination in Employment Act (“ADEA”) against the Sheriff's Office only (count ID.? ECF 22, at 5

L BACKGROUND □ "The following facts are taken from the operative complaint and, at the motion to dismiss stage, must be accepted as true. Erickson v. Pardus, 5 51 U.S. 89, 94 (2007). Demurjian was a □□□ year-old “Deputy Sheriff Trainee Recruit” with the Sheriff's Office after a forty-year career in law enforcement with other agencies. ECF 22, at 2 47-8. He alleges that on March 23, 2023, while he was “under instruction at the Harford County Sheriff’s Office Recruit Academy.” four Sheriff's Office deputies conducted an extensive search of Demurj ian’s vehicle at the direction of Dunbar. Id. at 3. § 12. The search occurred, without Demurjian’s knowledge or consent, without probable cause, and without a warrant. Id. J 13-14, The search uncovered “professional law enforcement entry tools, a canine catch pole, medical supplies, six rounds of snake shot, and a locked box.” Id.

3 The body of the operative complaint alleges “Defendant Sheriffs Office violated the Americans with Disabilities Act.” ECF 22, at 5 931. However, the heading lists the cause of action as a violation of the “Age Discrimination in Employment Act,” and the complaint otherwise makes clear that Plaintiff alleges discrimination based on age, not disability. See, e.g., id. at 1 J 1 (noting that Defendants’ conduct was carried out “on account of [Plaintiff’s] age”). 4 The Court references all filings by their respective ECF numbers and page numbers by the ECF-

_ generated page numbers at the top of the page.

{ 16. Plaintiff was then “removed from instruction and was escorted to his car by four [d]eputies, who acted, upon information and belief, at Defendant Dunbar’s request, and was ordered, against his will and without a warrant, to open and empty the contents of the locked box. All it contairied was Plaintiff's wallet.” fd. §] 17. “Subsequently, Plaintiff was interrogated by Defendant Dunbar and three other ranking members of the Sheriff's Office as to the reason he was in possession of rescue and mechanical equipment in his car. Plaintiff was not free to leave the interrogation and was not read his Fifth Amendment rights.” Jd. at 3-4] 18. Plaintiff alleges that no Sheriff's Office trainee recruits younger than Demurjian were “subjected to the same degree of scrutiny,” id. at 4 21, and that the search “was conducted to intimidate and harass Plaintiff due to his age, in order to cause him-to quit,” id. 722. “On the same day as the search, Plaintiff withdrew his application to [the Sheriff's Office] and has been unemployed since that date.” Id. ¥ 24. In the motion to dismiss, or, in the alternative for suramary judgment, Defendants □□□□□ that Demurjian failed to state a claim against Dunbar because he has not pled facts to establish a claim of supervisory liability under § 1983 for the allegedly unlawful search, ECF 25-1, at 5-7, and that he failed to allege facts to support an unlawful seizure claim against Dunbar for the alleged interrogation, especially considering the unique circumstances where the alleged Fourth Amendment violation was perpetrated by a government employer, id. at 7-8. Relying on the ©

affidavit submitted by Dunbar in which he attests that he “did not command, direct, or order the search of Mr. Demurjian’s vehicle,” ECF 25-4, at 2 6, Defendants further argue that summary judgment is appropriate on the illegal search claim, ECF 25-1, at 8. As to the age discrimination claim against only the Sherif? s Office, Defendants argue that the Sheriff's Office is not an entity capable of being sued and that the State of Maryland is otherwise is protected by sovereign immunity. fd. at 9-10.

Plaintiff responds that he brings a direct liability, not supervisory liability, claim against Dunbar for the search and that he has plausibly alleged such a claim. ECF 28, at 8-9. Plaintiff asserts that summary judgment is not appropriate on this claim prior to discovery. Id, at 10-11. While Plaintiff acknowledges that Rule 56(d) permits a party to submit an affidavit asserting that more discovery is needed to defeat a motion for summary judgment, id. at 6-7, he also asserts that “[nJo affidavit from Plaintiff is necessary” here because the “need for at least several depositions about who authorized officers to search a trainee’s car, if Dunbar did not, is apparent,” id. at 11. As to the seizure claim, Plaintiff asserts that he did not allege that the deputies were acting as a “sovernment employer,” and that in drawing all reasonable inferences in Plaintiff's favor, the complaint properly alleges that a reasonable person in Plaintiff's shoes would not have believed that he was free to leave. /d@ at 9-10.

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Demurjian v. Dunbar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/demurjian-v-dunbar-mdd-2025.