Estate of James Marshall v. City of Forest Grove

CourtDistrict Court, D. Oregon
DecidedOctober 5, 2023
Docket3:22-cv-01470
StatusUnknown

This text of Estate of James Marshall v. City of Forest Grove (Estate of James Marshall v. City of Forest Grove) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of James Marshall v. City of Forest Grove, (D. Or. 2023).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON PORTLAND DIVISION

ESTATE OF JAMES MARSHALL and SARA MARSHALL,

Plaintiffs, Case No. 3:22-cv-01470-YY

v. ORDER

CITY OF FOREST GROVE, STEVEN TEETS, KOLE MCGANN, and MATTHEW DORICK,

Defendants.

On October 3, 2023, plaintiffs and defendants City of Forest Grove, Kole McGann, and Matthew Dorick (collectively “defendants,” for purposes of this order) appeared for a telephonic hearing to obtain the court’s assistance in resolving discovery disputes. The court’s rulings are set forth in this order. I. Discovery Standards Federal Rule of Civil Procedure 26(b)(1) sets forth the scope of discovery: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. FED. R. CIV. P. 26(b)(1). The court may limit discovery that “is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive.” FED. R. CIV. P. 26(b)(2)(C)(i). The court has broad discretion to control discovery. Hallett v. Morgan, 296 F.3d 732, 751 (9th Cir. 2002). A decision to “deny discovery will not be disturbed except upon the clearest showing that denial of discovery results in actual and substantial prejudice to the complaining litigant.” Id. II. Monell Claims at Issue

Plaintiffs allege claims against the City of Forest Grove (“City”) and three Forest Grove Police Department officers arising from the death of James Marshall on October 7, 2020. Plaintiffs’ claims include (1) a Fourth Amendment excessive force claim against the individual officers, (2) state common law claims of assault and battery against the individual officers, and (3) claims against the City pursuant to Monell v. Dep’t of Social Services, 436 U.S. 658 (1978), based on its practice or custom of permitting officer misconduct to go undisciplined, failing to train the individual officers in de-escalation tactics when an individual is having a mental health crisis, including calling for assistance from the Washington County Mental Health Unit, and failing to train the individual officers on the reasonable use of force when detaining a person of interest.1 Compl., ECF 1.

Plaintiffs recently filed a Motion for Leave to Amend Complaint (ECF 25) in which they seek leave to “clarify” their Monell claims to allege that the individual defendants acted pursuant

1 Plaintiffs also included a final policymaker claim in their complaint, but are no longer pursuing that claim. an expressly adopted official policy or a widespread or longstanding practice of the police department with respect to unconstitutional use-of-force techniques applied to individuals suffering from mental health crises and/or excited delirium. Plaintiffs also move to include a failure to train claim, i.e., that the City failed to provide adequate training, and a ratification

claim, i.e., that the police chief ratified the individual officers’ acts or failures to act. Under Monell, the City may be liable for a constitutional violation based on: “(1) an official policy; (2) a pervasive practice or custom; (3) a failure to train, supervise, or discipline; or (4) a decision or act by a final policymaker.” Horton by Horton v. City of Santa Maria, 915 F.3d 592, 602-03 (9th Cir. 2019). A plaintiff also “may prove that an official with final policy- making authority ratified a subordinate’s unconstitutional decision or action and the basis for it.” Gillette v. Delmore, 979 F.2d 1342, 1346-47 (9th Cir. 1992). A “policy” is a “deliberate choice to follow a course of action . . . made from among various alternatives by the official or officials responsible for establishing final policy with respect to the subject matter in question.” Fogel v. Collins, 531 F.3d 824, 834 (9th Cir. 2008). A

“custom” is a “widespread practice that, although not authorized by written law or express municipal policy, is so permanent and well-settled as to constitute a custom or usage with the force of law.” St. Louis v. Praprotnik, 485 U.S. 112, 127 (1988); Los Angeles Police Protective League v. Gates, 907 F.2d 879, 890 (9th Cir. 1990). “The custom must be so ‘persistent and widespread’ that it constitutes a ‘permanent and well settled . . . policy.’” Trevino v. Gates, 99 F.3d 911, 918 (9th Cir. 1996) (quoting Monell, 436 U.S. at 691). “Liability for improper custom may not be predicated on isolated or sporadic incidents; it must be founded upon practices of sufficient duration, frequency and consistency that the conduct has become a traditional method of carrying out policy.” Id. The “first inquiry in any case alleging municipal liability under § 1983 is the question whether there is a direct causal link between a municipal policy or custom and the alleged constitutional deprivation.” Castro v. County of Los Angeles, 833 F.3d 1060, 1075 (9th Cir. 2016) (citation omitted). “A government entity may not be held liable under 42 U.S.C. § 1983,

unless a policy, practice, or custom of the entity can be shown to be a moving force behind a violation of constitutional rights.” Dougherty v. City of Covina, 654 F.3d 892, 900 (9th Cir. 2011). A plaintiff also must establish deliberate indifference, for example, that “the policy amounted to deliberate indifference of a constitutional violation,” Mabe v. San Bernardino Cty., 237 F.3d 1101, 1110-11 (9th Cir. 2001), or that “the deficiency in training actually caused the police officers’ indifference to her medical needs.” City of Canton, Ohio v. Harris, 489 U.S. 378, 391-92 (1989). “To adopt lesser standards of fault and causation would open municipalities to unprecedented liability under § 1983.” Id. “‘[D]eliberate indifference’ is a stringent standard of fault, requiring proof that a municipal actor disregarded a known or obvious consequence of

his action.” Bd. of Cty. Comm’rs of Bryan Cnty., Okl. v. Brown, 520 U.S. 397, 410 (1997). Unless there is a single violation with a “highly predictable consequence,” id. at 398, there must be a pattern of similar constitutional violations to demonstrate deliberate indifference, Connick v. Thompson, 563 U.S. 51, 62 (2011) (citing Bryan Cnty., 520 U.S. at 409).

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
City of St. Louis v. Praprotnik
485 U.S. 112 (Supreme Court, 1988)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Dougherty v. City of Covina
654 F.3d 892 (Ninth Circuit, 2011)
James Gillette v. Duane Delmore, and City of Eugene
979 F.2d 1342 (Ninth Circuit, 1992)
Lassiter v. City of Bremerton
556 F.3d 1049 (Ninth Circuit, 2009)
Fogel v. Collins
531 F.3d 824 (Ninth Circuit, 2008)
Jonathon Castro v. County of Los Angeles
833 F.3d 1060 (Ninth Circuit, 2016)
Shane Horton v. City of Santa Maria
915 F.3d 592 (Ninth Circuit, 2019)
Trevino v. Gates
99 F.3d 911 (Ninth Circuit, 1996)
Hallett v. Morgan
296 F.3d 732 (Ninth Circuit, 2002)
Connick v. Thompson
179 L. Ed. 2d 417 (Supreme Court, 2011)
Lytle v. Carl
382 F.3d 978 (Ninth Circuit, 2004)
Los Angeles Police Protective League v. Gates
907 F.2d 879 (Ninth Circuit, 1990)

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Estate of James Marshall v. City of Forest Grove, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-james-marshall-v-city-of-forest-grove-ord-2023.