Fidler v. Touchette

CourtVermont Superior Court
DecidedFebruary 28, 2020
Docket537-10-19 Wncv
StatusPublished

This text of Fidler v. Touchette (Fidler v. Touchette) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fidler v. Touchette, (Vt. Ct. App. 2020).

Opinion

Fidler v. Touchette, No. 537-10-19 Wncv (Tomasi, J., Feb. 28, 2020).

[The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

STATE OF VERMONT SUPERIOR COURT CIVIL DIVISION Washington Unit Docket No. 537-10-19 Wncv

Matthew Fidler, Plaintiff

v.

Michael P Touchette, Joshua Rutherford, Defendants

Opinion and Order on Defendants’ Motion to Dismiss

Plaintiff brings this claim against two corrections officials in their individual

and official capacities. He asserts claims under the federal Constitution and

Vermont tort law arising out of an alleged slip and fall that occurred at a

correctional facility and the allegedly inadequate medical care that he received. He

seeks monetary damages for his alleged injuries. Defendants have moved to

dismiss on various grounds. Plaintiff has opposed the motion. The Court makes

the following determinations.

I. The Standard

The Vermont Supreme Court disfavors Rule 12(b)(6) motions to dismiss.

“Dismissal under Rule 12(b)(6) is proper only when it is beyond doubt that there

exist no facts or circumstances consistent with the complaint that would entitle

Plaintiff to relief.” Bock v. Gold, 2008 VT 81, ¶ 4, 184 Vt. 575, 576 (mem.) (quoting

Union Mut. Fire Ins. Co. v. Joerg, 2003 VT 27, ¶ 4, 175 Vt. 196, 198)). In considering a motion to dismiss, the Court “assume[s] that all factual allegations

pleaded in the complaint are true, accept[s] as true all reasonable inferences that

may be derived from plaintiff's pleadings, and assume[s] that all contravening

assertions in defendant's pleadings are false.” Mahoney v. Tara, LLC, 2011 VT 3,

¶ 7, 189 Vt. 557, 559 (mem.) (internal quotation, brackets, and ellipses omitted).

II. The Federal Constitutional Claims

A. Official Capacity Claims

Plaintiff has asserted what amount to claims for deprivations of his

constitutional rights under the United States Constitution. Such claims must be

brought pursuant to 42 U.S.C. § 1983. As Defendants correctly argue, however, a

constitutional claim for retrospective money damages against a state official in his

official capacity cannot be maintained under Section 1983. The United States

Supreme Court has made clear that a state official in his “official capacity” is not “a

person” subject to suit under Section 1983. Will v. Michigan, 491 U.S. 58, 71 (1989);

Edelman v. Jordan, 415 U.S. 651, 663-65 (1974); accord J. Endres v. Ne. Ohio Med.

Univ., No. 18-3825, 2019 WL 4125263, at *10 (6th Cir. Aug. 30, 2019) (“state

defendants acting in their official capacities are not ‘persons’ under § 1983 with

respect to claims for monetary damages”).1

The federal claims against Defendants in their official capacities are

dismissed.

1 A plaintiff may sue a state official under Section 1983 to obtain forward-looking injunctive relief. Ex Parte Young, 209 U.S. 123, 159-60 (1908). Plaintiff has not sought such a remedy in this case. 2 B. Individual Capacity Claims

Plaintiff’s claims against Defendants in their individual capacities fare

better, at least at this early stage. As an initial matter, claims against an

individual state official for violations of federal constitutional rights are cognizable

under Section 1983. Defendants’ motion challenges the Complaint by asserting that

it does not allege that the Defendant had sufficient “personal involvement” with the

alleged constitutional violations to state a claim. Indeed, the law is well settled that

supervisors cannot be held liable under Section 1983 simply because of their status

as supervisors. Instead, they must have played a meaningful role in the

constitutional violation. See, e.g., Bass v. Jackson, F.2d 260, 263 (2d Cir. 1986).

Relying on federal precedent, the Defendants argue that Plaintiff must set out

sufficient facts in the Complaint to support his claim for supervisory liability. The

Court disagrees.

Whatever is required procedurally in federal court, under existing Vermont

precedent, a complaint need not provide such detail. Instead, it need only provide a

“short and plain statement of the claim showing that the pleader is entitled to

relief.” Vt. R. Civ. P. 8. The rule that a complaint need only “’provide[ ] the

defendant with notice of the claims against it’ is an attempt to strike a balance

between ‘encouraging valid, but as yet underdeveloped, causes of action and

discouraging baseless or legally insufficient ones,’ mindful that the complaint's

‘purpose is to initiate the cause of action, not prove the merits of the plaintiff's case.’

3 Colby v. Umbrella, Inc., 2008 VT 20, ¶ 13, 184 Vt. 1, 955 A.2d 1082.” Sutton v.

Vermont Reg’l Ctr., 2019 VT 71, ¶ 20 (Vt. Oct. 4, 2019).

In this instance, the Complaint is sufficient to put Defendants on notice of

the alleged supervisory claim. It need not go into detail as to the precise level of

personal involvement because the Court can only dismiss if there are no set of facts

consistent with the Complaint that could warrant relief. Bock, 2008 VT 81, ¶ 4, 184

Vt. at 576. It cannot make that determination here.

A similar result ensues with regard to Defendants’ assertion that the

Complaint fails to allege that Defendants were “deliberately indifferent” to his

medical care. No doubt, that is the correct standard that Plaintiff will need to meet

to establish his claim. The Complaint is not fatally defective, however, for failing to

employ that precise language.

The motion to dismiss the Section 1983 claims against Defendants in their

individual capacities is denied.

III. The State Tort Claims

Claims against state officials for torts committed in the course of their duties

are governed by the Vermont Tort Claims Act (VTCA). 12 V.S.A. §§ 5601-08. The

VTCA requires that negligence claims be brought against the “State of Vermont.”

This Court has already ruled that, in this context, a claim against a state official in

his official capacity is not cognizable under the VTCA. See Blatt v. Touchette,

Docket No. 286-5-19 Wncv (Sept. 9, 2019). The Court adheres to that

determination.

4 Accordingly, the tort claims against both Defendants in their official

capacities are dismissed.2

A. Defendant Touchette – Individual Capacity

Defendant Touchette was the Commissioner of Corrections. State law

provides that such officials are absolutely immune from suit. See Curran v.

Marcille, 152 Vt. 247, 248-49 (1989).

That VTCA claims against Defendant Touchette in his individual capacity

are dismissed.

B. Defendant Rutherford -- Individual Capacity

Defendant Rutherford argues that the Complaint should be dismissed

against him in his personal capacity because Plaintiff’s cause of action for

negligence is rightly brought solely against the State. 12 V.S.A. § 5602. He is

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Edelman v. Jordan
415 U.S. 651 (Supreme Court, 1974)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Curran v. Marcille
565 A.2d 1362 (Supreme Court of Vermont, 1989)
Union Mutual Fire Insurance v. Joerg
2003 VT 27 (Supreme Court of Vermont, 2003)
Colby v. Umbrella, Inc.
2008 VT 20 (Supreme Court of Vermont, 2008)
Bock v. Gold
2008 VT 81 (Supreme Court of Vermont, 2008)
Anthony Sutton v. Vermont Regional Center
2019 VT 71 (Supreme Court of Vermont, 2019)
Mahoney v. Tara, LLC
2011 VT 3 (Supreme Court of Vermont, 2011)

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Bluebook (online)
Fidler v. Touchette, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fidler-v-touchette-vtsuperct-2020.