Easley v. State of Missouri

CourtDistrict Court, E.D. Missouri
DecidedSeptember 25, 2024
Docket2:24-cv-00034
StatusUnknown

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

Bluebook
Easley v. State of Missouri, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

JUSTIN ARDIS EASLEY, ) ) Plaintiff, ) ) v. ) No. 2:24-cv-00034-SPM ) STATE OF MISSOURI, et al., ) ) Defendants. )

OPINION, MEMORANDUM AND ORDER This matter is before the Court on Plaintiff Justin Ardis Easley’s Motion to Proceed in Forma Pauperis. (ECF No. 2). Having reviewed the financial information provided in support, the Court finds that Plaintiff is unable to pay the filing fee. The Court will therefore grant the motion. Additionally, for the reasons discussed below, the Court will give Plaintiff an opportunity to amend his Complaint. Legal Standard on Initial Review Under 28 U.S.C. § 1915(e)(2), the Court may dismiss a complaint filed in forma pauperis if the action is frivolous or malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief against a defendant who is immune from such relief. When reviewing a complaint filed by a self-represented person under 28 U.S.C. § 1915, the Court accepts the well- pleaded facts as true, White v. Clark, 750 F.2d 721, 722 (8th Cir. 1984), and liberally construes the complaint. Erickson v. Pardus, 551 U.S. 89, 94 (2007); Haines v. Kerner, 404 U.S. 519, 520 (1972). A “liberal construction” means that if the essence of an allegation is discernible, the district court should construe the complaint in a way that permits the claim to be considered within the proper legal framework. Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015). Even so, self- represented plaintiffs must allege facts which, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980); see also Stone v. Harry, 364 F.3d 912, 914-15 (8th Cir. 2004) (refusing to supply additional facts or to construct a legal theory for the self-represented plaintiff).

To sufficiently state a claim for relief, a complaint must plead more than “legal conclusions” and “[t]hreadbare recitals of the elements of a cause of action [that are] supported by mere conclusory statements.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A plaintiff must demonstrate a plausible claim for relief, which is more than a “mere possibility of misconduct.” Id. at 679. “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. at 678. Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw on its judicial experience and common sense. Id. at 679. The Complaint

Plaintiff brings this case under 42 U.S.C. § 1983 against Matthew Wilt (Police Officer), Jacob Nacke (Chief of Police), the Hannibal Police Department, the Board of Police Commissioners, and the State of Missouri.1 According to Plaintiff, in July 2021, Officer Wilt planted drugs “in the dwelling [Plaintiff] was stabbed behind . . . which [Officer Wilt] fraudulently claimed to be [Plaintiff’s] home” and confiscated Plaintiff’s “legally possessed firearm.” Plaintiff states that Officer Wilt “delayed emergent medical care . . . causing him to suffer major loss of blood and unnecessary pain.” He further asserts that Officer Wilt “turned him into a suspect in drug distribution of meth without reasonable suspicion or probable cause to believe such a false

1 Defendants’ job titles are included in parentheses as alleged by Plaintiff. allegation[.]” Plaintiff contends that Officer Wilt “arrested and incarcerated” him in August 2023 without probable cause and on the basis of the planted evidence. He attributes Officer Wilt’s conduct to racial animus. Plaintiff seeks compensatory damages “jointly and [severally] against all defendants in the amount of $5,000,000” and punitive damages against Officer Wilt in the

amount of $15,000,000. He also seeks a restraining order against all defendants. Discussion Plaintiff asserts the following claims against Officer Wilt: (1) false imprisonment, (2) malicious prosecution, (3) “false light invasion of privacy and/or defamation of [Plaintiff’s] character,” and (4) illegal seizure of his firearm. He also asserts municipal liability against the Hannibal Police Department, the Board of Police Commissioners, Chief Nacke, and the State of Missouri. For the reasons discussed below, the Court will dismiss Plaintiff’s claims against Chief Nacke, the Hannibal Police Department, the Board of Police Commissioners, and the State of Missouri. The Court will allow Plaintiff to amend his Complaint as against Officer Wilt in his individual capacity.

1. The Hannibal Police Department and the Board of Police Commissioners It is well established that a police department, as a department of local government, is not a distinct entity subject to suit. See, e.g., Owens v. Scott Cnty. Jail, 328 F.3d 1026, 1027 (8th Cir. 2003) (affirming summary judgment in favor of county jail because “county jails are not legal entities amendable to suit.”); Ketchum v. City of West Memphis, Ark., 974 F.2d 81, 82 (8th Cir. 1992) (stating that “departments or subdivisions” of local government are not “juridical entities suable as such”); De La Garza v. Kandiyohi Cty. Jail, 18 Fed. Appx. 436, 437 (8th Cir. 2001) (affirming district court’s dismissal of county jail and sheriff’s department as parties because they are not suable entities). For this reason, the Court will dismiss Plaintiff’s claims against the Hannibal Police Department and the Board of Police Commissioners.2 2. Chief Nacke Plaintiff does not indicate whether he is suing Chief Nacke in his official or individual

capacity. As a result, the Court interprets the Complaint to include only official-capacity claims against Chief Nacke. See Baker v. Chisom, 501 F.3d 920, 923 (8th Cir. 2007) (stating that if a plaintiff’s complaint is silent as to capacity, the court interprets the complaint as including only official-capacity claims); Johnson v. Outboard Marine Corp., 172 F.3d 531, 535 (8th Cir. 1999) (“[I]n order to sue a public official in his or her individual capacity, a plaintiff must expressly and unambiguously state so in the pleadings, otherwise, it will be assumed that the defendant is sued only in his or her official capacity.”). An official-capacity claim against an individual is a claim “against the governmental entity itself.” See White v. Jackson, 865 F.3d 1064, 1075 (8th Cir. 2017). Put another way, a “suit against a public employee in his or her official capacity is merely a suit against the public employer.”

Johnson v. Outboard Marine Corp., 172 F.3d 531, 535 (8th Cir.

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Erickson v. Pardus
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Ashcroft v. Iqbal
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Johnson v. Outboard Marine Corp.
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Samvel Topchian v. JPMorgan Chase Bank, N.A.
760 F.3d 843 (Eighth Circuit, 2014)
James Solomon v. Deputy U.S. Marshal Thomas
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Easley v. State of Missouri, Counsel Stack Legal Research, https://law.counselstack.com/opinion/easley-v-state-of-missouri-moed-2024.