Foley v. Pacchiega

CourtDistrict Court, D. Nevada
DecidedJune 17, 2020
Docket2:15-cv-02047
StatusUnknown

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

Bluebook
Foley v. Pacchiega, (D. Nev. 2020).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * * 5 MICHAEL FOLEY, Case No. 2:15-cv-02047-JCM-DJA 6 Plaintiff, 7 ORDER v. 8 FERNANDO PACCHIEGA, et al., 9 Defendants. 10 11 This matter is before the Court on remand from the Ninth Circuit. Plaintiff’s request to 12 proceed in forma pauperis was granted and his Second Amended Complaint was found to not be 13 barred under Heck v. Humphrey, 512 U.S. 477 (1994) as he alleged he had not been arrested or 14 convicted for a criminal offense given that the arrest in question was for civil contempt. 15 Accordingly, as Plaintiff has been granted in forma pauperis status, his Second Amended 16 Complaint (ECF No. 8) is ripe for screening. 17 Upon granting an application to proceed in forma pauperis, courts additionally screen the 18 complaint pursuant to 28 U.S.C. § 1915(e). Federal courts are given the authority to dismiss a case 19 if the action is legally “frivolous or malicious,” fails to state a claim upon which relief may be 20 granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. 21 § 1915(e)(2). When a court dismisses a complaint under § 1915, the plaintiff should be given leave 22 to amend the complaint with directions as to curing its deficiencies, unless it is clear from the face 23 of the complaint that the deficiencies could not be cured by amendment. See Cato v. United States, 24 70 F.3d 1103, 1106 (9th Cir. 1995). 25 Rule 12(b)(6) of the Federal Rules of Civil Procedure provides for dismissal of a complaint 26 for failure to state a claim upon which relief can be granted. Review under Rule 12(b)(6) is 27 essentially a ruling on a question of law. See Chappel v. Lab. Corp. of Am., 232 F.3d 719, 723 (9th 1 showing that the pleader is entitled to relief. Fed.R.Civ.P. 8(a)(2); Bell Atlantic Corp. v. Twombly, 2 550 U.S. 544, 555 (2007). Although Rule 8 does not require detailed factual allegations, it demands 3 “more than labels and conclusions” or a “formulaic recitation of the elements of a cause of action.” 4 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Papasan v. Allain, 478 U.S. 265, 286 (1986)). 5 The court must accept as true all well-pled factual allegations contained in the complaint, but the 6 same requirement does not apply to legal conclusions. Iqbal, 556 U.S. at 679. Mere recitals of the 7 elements of a cause of action, supported only by conclusory allegations, do not suffice. Id. at 678. 8 Secondly, where the claims in the complaint have not crossed the line from conceivable to 9 plausible, the complaint should be dismissed. Twombly, 550 U.S. at 570. Allegations of a pro se 10 complaint are held to less stringent standards than formal pleadings drafted by lawyers. Hebbe v. 11 Pliler, 627 F.3d 338, 342 & n.7 (9th Cir. 2010) (finding that liberal construction of pro se pleadings 12 is required after Twombly and Iqbal). 13 In this case, Plaintiff attempts to bring claims under 42 U.S.C. § 1983 against two police 14 officers in their individual and official capacities, former Sheriff Gillespie, the Las Vegas 15 Metropolitan Police Department, two attorneys, a card dealer, a video cameraman, and Clark 16 County. (ECF No. 8). He seeks damages along with injunctive relief for alleged false arrest and 17 false imprisonment. Further, Plaintiff appears to attempt to state a claim for violation of his due 18 process rights under the Fourteenth Amendment because when he arrived at the residence of 19 Patricia Foley, his ex-wife, he was denied entry by her and Juan Carlos Valdes, which resulted in 20 a report being filed with the LVMPD. He further alleges that he was later detained and arrested 21 for civil contempt, which violated the Fourth Amendment. 22 42 U.S.C. § 1983 creates a path for the private enforcement of substantive rights created 23 by the Constitution and Federal Statutes. Graham v. Connor, 490 U.S. 386, 393-94 (1989). To 24 the extent that Plaintiff is seeking to state a claim under § 1983, a plaintiff “must allege the 25 violation of a right secured by the Constitution and the laws of the United States, and must show 26 that the alleged deprivation was committed by a person acting under color of law.” West v. 27 Atkins, 487 U.S. 42, 48-49 (1988). A person acts under “color of law” if he “exercise[s] power 1 possessed by virtue of state law and made possible only because the wrongdoer is clothed with 2 the authority of state law.” Id. 3 Plaintiff does not allege that Foley or Valdes were acting under the color of law and the 4 Court cannot infer based on the allegations provided in the Second Amendment Complaint that he 5 can state a viable Section 1983 claim against them. Similarly, for the attorneys named as 6 Defendants, Plaintiff does not articulate how they acted under color of state law or if they were 7 employed as attorneys for the government, which may involve an issue of immunity. He will be 8 given leave to amend to clarify what claim or claims he is attempting to state against those 9 Defendants. 10 Plaintiff has also failed to show that the LVMPD is subject to 1983 liability. In Monell v. 11 Department of Social Services, 436 U.S. 658 (1978), the Supreme Court held that a municipality 12 could be held liable under Section 1983 if an official policy or custom directly caused the 13 violation of an individual's constitutional rights. A plaintiff must establish “(1) that he possessed 14 a constitutional right of which he was deprived; (2) that the municipality had a policy; (3) that this 15 policy ‘amounts to deliberate indifference’ to the plaintiff’s constitutional right; and (4) that the 16 policy is the ‘moving force behind the constitutional violation.’” Oviatt v. Pearce, 954 F.2d 17 1470, 1474 (9th Cir.1992) (quoting City of Canton v. Harris, 489 U.S. 378, 389–91 (1989)). A 18 plaintiff cannot prove the existence of a municipal policy or custom based only on the occurrence 19 of a single constitutional violation by a law enforcement officer. Davis v. City of Ellensburg, 869 20 F.2d 1230, 1233 (9th Cir. 1989). However, a policy “may be inferred from widespread practices 21 or ‘evidence of repeated constitutional violations for which the errant municipal officers were not 22 discharged or reprimanded.’” Nadell v. LVMPD, 268 F.3d 924, 929 (9th Cir. 2001) (quoting 23 Gillette v. Delmore, 979 F.2d 1342, 1349 (9th Cir. 1992)).

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Hafer v. Melo
502 U.S. 21 (Supreme Court, 1991)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hebbe v. Pliler
627 F.3d 338 (Ninth Circuit, 2010)
United States v. Hector Garcia
954 F.2d 12 (First Circuit, 1992)
James Gillette v. Duane Delmore, and City of Eugene
979 F.2d 1342 (Ninth Circuit, 1992)
Cato v. United States
70 F.3d 1103 (Ninth Circuit, 1995)

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Foley v. Pacchiega, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foley-v-pacchiega-nvd-2020.