Fletcher v. Cordell

CourtDistrict Court, W.D. Arkansas
DecidedMay 5, 2020
Docket3:20-cv-03032
StatusUnknown

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

Bluebook
Fletcher v. Cordell, (W.D. Ark. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HARRISON DIVISION JESSIE EDWARD FLETCHER PLAINTIFF Vv. CASE NO. 3:20-CV-03032 DEPUTY BILLY CORDELL and CHIEF DEPUTY PIERCE DEFENDANTS OPINION AND ORDER Plaintiff Jessie E. Fletcher (“Fletcher”), currently an inmate of the Searcy County Detention Center, filed this civil rights action pursuant to 42 U.S.C. § 1983. He proceeds pro se and in forma pauperis (“IFP’). The case is before the Court for preservice screening under the provisions of the Prison Litigation Reform Act ("PLRA”). Pursuant to 28 U.S.C. § 1915A, the Court has the obligation to screen any complaint in which a prisoner seeks to proceed IFP. 28 U.S.C. § 1915A(a). The Court must determine whether the Complaint should be served on Defendants. |. BACKGROUND According to the Complaint (Doc. 1), on April 3, 2019, Deputy Cordell (“Cordell”) faisely wrote on a Miranda rights form that Fletcher had a twelfth grade education rather than an eighth grade education; Cordell failed to note that Fletcher terminated the interview and asked for an attorney; and Cordell attempted to coerce Fletcher into confessing to a burglary charge. Fletcher alleges Cordell threatened to have him charged with kidnapping and attempted murder if he did not confess to the burglary. Fletcher also alleges Cordell coached him on what to say when he confessed. According ]

to Fletcher, Cordell worked with Chief Deputy Pierce (“Pierce”) and both made threats against him. Although Fletcher did not list Pierce as a Defendant, Fletcher's statement of his claim contains repeated allegations against Pierce. For this reason, the Court considers Pierce to be a named Defendant. Fletcher alleges Pierce questioned him on April 10, 2019, despite the fact that Fletcher asked for an attorney; lied in documentation stating that Fletcher owned a vehicle that appeared in a video of the burglary; attempted to get Fletcher to confess; told Fletcher to indicate that he had completed the twelfth grade; and obtained search warrants for phones belonging to Fletcher's wife and sister-in-law.’ As relief, Fletcher seeks compensatory and punitive damages. ll. LEGAL STANDARD Under the PLRA, the Court is obliged to screen the case prior to service of process being issued. The Court must dismiss a complaint, or any portion of it, if it contains claims that: (1) are frivolous, malicious, or fail to state a claim upon which relief may be granted, or (2) seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). A claim is frivolous if “it lacks an arguable basis either in law or fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). A claim fails to state a claim upon which relief may be granted if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “In evaluating whether

' Fletcher asserted virtually identical claims against Pierce in Fletcher v. Pierce, et al., Civil No. 3:20-cv-03021.

a pro se plaintiff has asserted sufficient facts to state a claim, we hold ‘a pro se complaint, however inartfully pleaded . . . to less stringent standards than formal pleadings drafted by lawyers.” Jackson v. Nixon, 747 F.3d 537, 541 (8th Cir. 2014) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)). However, mere conclusory allegations with no supporting factual averments are insufficient to state a claim upon which relief can be based. Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004). “[A] pro se plaintiff requires no special legal training to recount the facts surrounding his alleged injury, and he must provide such facts if the court is to determine whether he makes out a claim on which relief can be granted.” Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991) (citations omitted). ill. DISCUSSION To state a claim under § 1983, Fletcher must show: (1) that Defendants acted under color of state law, and (2) that the alleged wrongful conduct deprived him of a constitutionally protected federal right. Schmidt v. City of Bella Villa, 557 F.3d 564, 571 (8th Cir. 2009). A. The Miranda Claims In Miranda v. Arizona, 384 U.S. 436, 444 (1966), the United States Supreme Court held that the Fifth Amendment privilege against self-incrimination prohibits the admission into evidence of statements given by a suspect during “custodial interrogation.” In general, once an individual invokes his right to counsel custodial interrogation must cease. Moran v. Burbine, 475 U.S. 412, 433 n.4 (1986). If statements obtained during custodial interrogation are not used against a party, there is no constitutional violation.

Davis v. City of Charleston, 827 F.2d 317, 322 (8th Cir. 1987). ‘(Al litigant cannot maintain an action under § 1983 based on a violation of the Miranda safeguards. . . . [Th]Je remedy for a Miranda violation is the exclusion of evidence of any compelled self-incrimination, not a section 1983 action.” Hannon v. Sanner, 441 F.3d 635, 636 (8th Cir. 2006) (internal quotation marks and citations omitted). Fletcher's Miranda claims fail to state claims upon which relief may be granted. B. Verbal Threats and Harassment Claims To the extent Fletcher's claims are based on threats made by Cordell and Pierce, the claims fail. “Verbal threats do not constitute a constitutional violation.” Martin v. Sargent, 780 F.2d 1334, 1339 (8th Cir. 1985). Similarly, taunts, name calling, and the use of offensive language do not state a claims of constitutional dimension. McDowell v. Jones, 990 F.2d 433, 434 (8th Cir. 1993) (inmate’s claims of general harassment and of verbal harassment were not actionable under § 1983); O’Donnell v. Thomas, 826 F.2d 788, 790 (8th Cir. 1987) (verbal threats and abuse by jail officials did not rise to the level of a constitutional violation). Fletcher's claims based on verbal threats and harassment fail because they are not cognizable under § 1983. C. Cell Phone Search Claims Fletcher also appears to be asserting a claim against Pierce stemming from the search of two cell phones. Fletcher objects because the phones were his wife’s and sister-in-law's and because the warrant covered all content for a period of a year. Fletcher, however, does not deny that a search warrant was issued for these cell

phones. He does not allege the search warrant was issued in violation of the Fourth Amendment.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Franks v. Delaware
438 U.S. 154 (Supreme Court, 1978)
United States v. Karo
468 U.S. 705 (Supreme Court, 1984)
Moran v. Burbine
475 U.S. 412 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Schmidt v. City of Bella Villa
557 F.3d 564 (Eighth Circuit, 2009)
Randall Jackson v. Jay Nixon
747 F.3d 537 (Eighth Circuit, 2014)
Martin v. Sargent
780 F.2d 1334 (Eighth Circuit, 1985)
Davis v. City of Charleston
827 F.2d 317 (Eighth Circuit, 1987)
Hall v. Bellmon
935 F.2d 1106 (Tenth Circuit, 1991)

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Bluebook (online)
Fletcher v. Cordell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-v-cordell-arwd-2020.