Estate of Nicholas Eugene McMain v. City of Hartford, Kentucky

CourtDistrict Court, W.D. Kentucky
DecidedMarch 5, 2020
Docket4:19-cv-00041
StatusUnknown

This text of Estate of Nicholas Eugene McMain v. City of Hartford, Kentucky (Estate of Nicholas Eugene McMain v. City of Hartford, Kentucky) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Nicholas Eugene McMain v. City of Hartford, Kentucky, (W.D. Ky. 2020).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY OWENSBORO DIVISION

CIVIL ACTION NO. 4:19CV-00041-JHM ESTATE OF NICHOLAS EUGENE MCMAIN PLAINTIFF By and through Angie Bullock, Administratrix

v.

JEAN NOFFSINGER DEFENDANT

MEMORANDUM OPINION AND ORDER This matter is before the Court on a motion by Defendant, Jean Noffsinger, to dismiss Plaintiff’s Second Amended Complaint against her [DN 40]. Fully briefed, this matter is ripe for decision. I. BACKGROUND On September 5, 2018, Nicholas McMain died while an inmate at the Ohio County Detention Center in Hartford, Kentucky. Plaintiff, Estate of Nicholas Eugene McMain, by his Administratrix Angie Bullock, brought this action on April 5, 2019, for violations of McMain’s rights under the Eighth and Fourteenth Amendments of the United States Constitution under 42 U.S.C. § 1983, negligence, wrongful death, failure to train, and failure to supervise. [DN 1]. In the original complaint, Plaintiff asserted claims against the City of Hartford, Jailer Gerry Wright, Howard Dean Minton, Jason Geary, and Chad Woods. On April 16, 2019, Plaintiff filed an amended complaint adding Mayor George Chinn in his individual capacity. On December 19, 2019, Plaintiff filed a motion for leave to add additional parties. [DN 34]. The motion was granted. [DN 36]. The second amended complaint added Jean Noffsinger as a defendant in this matter. [DN 37]. After the newly filed second amended complaint, Noffsinger filed this motion to dismiss arguing that Plaintiff’s claims against her are barred by the applicable statute of limitations. II. STANDARD OF REVIEW Upon a motion to dismiss for failure to state a claim pursuant to Fed. R. Civ. P. 12(b)(6), a court “must construe the complaint in the light most favorable to plaintiff,” League of United Latin Am. Citizens v. Bredesen, 500 F.3d 523, 527 (6th Cir. 2007) (citation omitted), “accept all well-pled factual allegations as true[,]” id., and determine whether the “complaint states a plausible

claim for relief[,]” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). Under this standard, the plaintiff must provide the grounds for his or her entitlement to relief which “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). A plaintiff satisfies this standard only when he or she “pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. A complaint falls short if it pleads facts “merely consistent with a defendant’s liability” or if the alleged facts do not “permit the court to infer more than the mere possibility of misconduct.” Id. at 678–679. Instead, the allegations must “‘show[ ] that the pleader is entitled to relief.’” Id. at 679 (quoting Fed. R. Civ. P. 8(a)(2)).

III. DISCUSSION Noffsinger moves to dismiss the claims against her arguing that the claims are barred by the statute of limitations. In response to this argument, Plaintiff argues that Noffsinger waived the right to raise a statute of limitations defense because her counsel agreed to extend the scheduling order deadline to add additional parties and failed to object to Plaintiff’s motion to add an additional party. Initially, the Court finds that Noffsinger did not waive the applicable statute of limitations. Until the complaint was amended, Noffsinger was not a party to the present action, and, therefore, she had no obligation to respond. She has timely raised the statute of limitations affirmative defense in her motion to dismiss. The statute of limitations for 42 U.S.C. § 1983 actions is governed by the limitations period for personal injury cases in the state in which the cause of action arose. Wallace v. Kato, 549 U.S. 384, 387 (2007). In Kentucky, § 1983 actions are limited by the one-year statute of limitations found in KRS § 413.140(1). Collard v. Kentucky Bd. of Nursing, 896 F.2d 179, 182 (6th Cir.

1990). The statute of limitations for wrongful death claims brought under KRS § 411.130 is also one year. Gaither v. Commonwealth, 161 S.W.3d 345, 346 (Ky. Ct. App. 2004) (quoting Conner v. George W. Whitesides Co., 834 S.W.2d 652, 653–654 (Ky. 1992)). KRS § 413.180(1) extends the time for filing an action resulting in the death of a person for up to one year after the qualification of the decedent’s personal representative. Conner, 834 S.W.2d at 655. McMain died on September 5, 2018, and Bullock was appointed executrix of his estate on October 18, 2018. Accordingly, Bullock had one year following her qualification as executrix, or until October 18, 2019, to file suit against any remaining defendants for McMain’s death. Plaintiff’s motion for leave to add additional parties was filed on December 19, 2019. [DN 34]. The second amended

complaint added Noffsinger as an additional defendant [DN 37] and is untimely absent a relation back to the original complaint or amended complaint. If a motion to amend a complaint is filed after the expiration of the statute of limitation, Fed. R. Civ. P. 15(c)1 allows an amended complaint to relate back to the original date of filing.

1 Subsection (c) of Rule 15 states that an amendment to a pleading relates back to the original time of filing when: (A) the law that provides the applicable statute of limitations allows relation back; (B) the amendment asserts a claim or defense that arose out of the conduct, transaction, or occurrence set out—or attempted to be set out—in the original pleading; or (C) the amendment changes the party or the naming of the party against whom a claim is asserted, if Rule 15(c)(1)(B) is satisfied and if, within the period provided by Rule 4(m) for serving the summons and complaint, the party to be brought in by amendment: (i) received such notice of the action that it will not be prejudiced in defending on the merits; and (ii) knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party’s identity. Fed. R. Civ. P. 15(c)(1)(A)–(C). “The purpose underlying the ‘relation back’ doctrine is to permit amendments to pleadings when the limitations period has expired.” Shillman v. United States, No. 99-3215, 221 F.3d 1336, 2000 WL 923761 (6th Cir. June 29, 2000). However, relation back is only available when changing a party because there was “a mistake concerning the proper party’s identity.” Fed. R. Civ. P. 15(c)(1)(C)(ii).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Rashoun Smith v. City of Akron
476 F. App'x 67 (Sixth Circuit, 2012)
Mackenzie Brown v. Cuyahoga County, Ohio
517 F. App'x 431 (Sixth Circuit, 2013)
Asher v. Unarco Material Handling, Inc.
596 F.3d 313 (Sixth Circuit, 2010)
Conner v. George W. Whitesides Co.
834 S.W.2d 652 (Kentucky Supreme Court, 1992)
Gaither v. Commonwealth
161 S.W.3d 345 (Court of Appeals of Kentucky, 2004)
Moore v. State of Tenn.
267 F. App'x 450 (Sixth Circuit, 2008)
Cox v. Treadway
75 F.3d 230 (Sixth Circuit, 1996)
Ham v. Sterling Emergency Services of the Midwest, Inc.
575 F. App'x 610 (Sixth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Estate of Nicholas Eugene McMain v. City of Hartford, Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-nicholas-eugene-mcmain-v-city-of-hartford-kentucky-kywd-2020.