Fletcher v. Ray

CourtDistrict Court, S.D. Texas
DecidedJuly 21, 2021
Docket3:20-cv-00362
StatusUnknown

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

Bluebook
Fletcher v. Ray, (S.D. Tex. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT July 21, 2021 Nathan Ochsner, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION HEIRS OF ESTATE OF ISAAC O. § CHAPA, et al., § § Plaintiffs, § 3:20-cv-00362 §

v. §

§ CITY OF ALVIN, et al., § § Defendants. §

MEMORANDUM OPINION AND ORDER

JEFFREY VINCENT BROWN, UNITED STATES DISTRICT JUDGE.

In this case, the survivors of Isaac O. Chapa III bring multiple claims against the City of Alvin and several police officers. Before the court is the defendants’ motion to dismiss (Dkt. 8). I. Background In July 2018, Alvin Police received a 911 call reporting that Isaac Chapa was suicidal and had fired a gun inside his home.1 Officers responded but discovered that Chapa had fled on a motorcycle, taking the firearm with him.2

1 Dkt 6 ¶¶ 12-13. 2 Id. ¶¶ 14, 16. Officers soon found Chapa’s motorcycle at a nearby church.3 They then spotted Chapa, who was still armed and threatening to kill himself.4 The officers

ordered him to throw his weapon to the ground and surrender, but did not otherwise try to calm him down or persuade him not to commit suicide.5 After Chapa finally dropped the gun, the officers told him to get on the ground.6 But he refused.

Instead, Chapa pleaded with the officers: “Shoot me.”7 As the situation reached a stalemate, Chapa picked up his gun and pointed it at his temple.8 Officer

Justin Garcia then shot Chapa.9 The other officers also opened fire, and Chapa fell to the ground.10 The officers rushed to Chapa but—before administering aid—rolled him onto

his chest and handcuffed him.11 Then they rolled him back over again.12 An officer

3 Id. ¶ 15. 4 Id. ¶ 16. 5 Id. ¶¶ 17–18. 6 Id. ¶¶ 21–22. 7 Id. ¶ 23. 8 Id. ¶ 24. 9 Id. ¶ 28. 10 Id. ¶¶ 28–29. The defendants contest whether more than one officer opened fire on Chapa, see Dkt. 11 at 4 n.1, but the court must accept as true the plaintiffs’ allegations. See Cummings v. Premier Rehab Keller, PLLC, 948 F.3d 673, 675 (5th Cir. 2020). 11 Id. ¶ 33. 12 Id. began first aid, but only after struggling to don a pair of medical gloves.13 EMS soon arrived and took Chapa to the hospital, where he was pronounced dead.14

The plaintiffs sued the City of Alvin, as well as officers Forest J. Hill, Margaret Ray, Joey Breaux, and Justin Garcia, alleging wrongful death and civil-rights

violations. Against the individual police officers, the plaintiffs assert excessive-force and delay-of-medical-care claims under 42 U.S.C. §§ 1983 and 1988. Against the City of Alvin, the plaintiffs assert municipal-liability claims, alleging failure to train,

ratification, and “pattern and practice.” The plaintiffs also seek punitive damages. The defendants have moved to dismiss the plaintiffs’ amended complaint under Rule 12(b)(6).15 They argue that the plaintiffs (1) failed to allege facts to state

a claim under any of their theories of liability either against the city or the individual officers, (2) failed to overcome the presumption of qualified immunity, and (3) failed to allege facts or state a claim under Texas law.

To survive a 12(b)(6) challenge, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”16

13 Id. 14 Id. ¶¶ 34–35. 15 Officer Joey Breaux is not a City of Alvin employee, and this motion is not made on his behalf. See Dkt. 8 at 1 n.3. 16 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The complaint is liberally construed in the plaintiff’s favor, and all pleaded facts must be taken as true.17 Mere legal conclusions will not suffice to state a claim.18

II. Analysis A. Claims under Sections 1985, 1986, and 1988

42 U.S.C. § 1985 establishes a cause of action for conspiracy to interfere with civil rights. To state a claim under § 1985(3), a plaintiff must allege facts that show “(1) a conspiracy involving two or more persons; (2) for the purpose of depriving,

directly or indirectly, a person or class of persons of the equal protection of the laws; and (3) an act of furtherance of the conspiracy; (4) which causes injury to a person or property, or a deprivation of any right or privilege of a citizen of the United

States.”19 A § 1986 claim, which provides a cause of action for neglect in preventing a conspiracy, is dependent on a § 1985 conspiracy claim.20

Section 1988 does not provide a substantive right or cause of action. Rather, it allows an award for attorneys’ and expert fees in an action under sections 1981–

17 Campbell v. Wells Fargo Bank, N.A., 781 F.2d 440, 442 (5th Cir. 1986). 18 See Iqbal, 556 U.S. at 678 (2009); see also McCoy v. Ku Ku, No. 3:17-CV-0275, 2018 WL 4220843, at *3 (S.D. Tex. Sept. 5, 2018). 19 Hilliard v. Ferguson, 30 F.3d 649, 652–53 (5th Cir. 1994). 20 42 U.S.C. § 1986; see Clark v. Clabaugh, 20 F.3d 1290, 1295 n.5 (3d Cir. 1994). 1986.21 It also authorizes courts to apply state common law “where federal law is unsuited or insufficient ‘to furnish suitable remedies,’” assuming that law is “not

inconsistent with the Constitution and laws of the United States.”22 The plaintiffs do not allege sufficient facts to state a claim under either § 1985 or § 1986.23 Their complaint mentions no conspiracy or any act in furtherance of a

conspiracy.24 In fact, the word “conspiracy” never appears in their amended complaint. Moreover, the defendants urging this motion are the City of Alvin and

some of its employees. As a matter of law, they comprise a single entity; the city and its employees cannot conspire merely among themselves.25 The plaintiffs’ claims under § 1985 and § 1986 must therefore be dismissed.

B. Fourteenth Amendment Delay-of-Medical-Care Claim The plaintiffs suggest that Chapa had a right to medical care under the Fourth Amendment.26 The Fifth Circuit has explained that a pretrial detainee has a

constitutional right to medical care, “whether in prison or other custody,” and that

21 Moor v. Alameda Cnty., 411 U.S. 693, 702–703 (1973). 22 Id. (quoting 42 U.S.C. § 1988). 23 See Dkt. 6 ¶ 10. 24 See generally id. 25 Hilliard, 30 F.3d at 653; Swilley v. City of Hous., 457 F. App’x 400, 404 (5th Cir. 2012) (per curiam). 26 See Dkt. 9 at 2. right “flows from the procedural and substantive due process guarantees of the Fourteenth Amendment.”27

Mirroring the Eighth Amendment standard, under the Fourteenth Amendment “[l]iability for failing to provide [medical care] attaches if the plaintiff

can show that a state official acted with deliberate indifference to a substantial risk of serious medical harm and that injuries resulted.”28 “Deliberate indifference is an extremely high standard to meet”—more than mere negligence.29 A plaintiff must

prove that “officials refused to treat him, ignored his complaints, intentionally treated him incorrectly, or engaged in any similar conduct that would clearly evince a wanton disregard for any serious medical needs.”30

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Fletcher v. Ray, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fletcher-v-ray-txsd-2021.