French v. Pierce County

CourtDistrict Court, W.D. Washington
DecidedFebruary 17, 2023
Docket3:22-cv-05079
StatusUnknown

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

Bluebook
French v. Pierce County, (W.D. Wash. 2023).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 THOMAS FRENCH, CASE NO. 3:22-cv-05079-DGE 11 Plaintiff, ORDER GRANTING IN PART 12 v. AND DENYING IN PART DEFENDANTS’ MOTIONS TO 13 PIERCE COUNTY et al., DISMISS (DKT. NOS. 18, 26) 14 Defendants. 15

16 I. INTRODUCTION 17 This matter comes before the Court on Defendants Pierce County, Aaron Wolfe, and 18 Jason Chavez’s Motions to Dismiss the First Amended Complaint (“FAC”). (Dkt. Nos. 18, 26.) 19 The Court considered the record and the pleadings filed in support of and in opposition to the 20 Motions and hereby grants them in part and denies them in part. 21 22 23 24 1 II. BACKGROUND 2 On November 3, 2019, “Curtis French was at home in Tacoma, [Washington] with 3 Crystal French (ex-wife and current girlfriend), Thomas French (son), Jordan French (daughter- 4 in-law), and his two grandsons.” (Dkt. No. 15 at 2.)

5 Curtis French had been heavily drinking and was inebriated. (Id.) At some point, Curtis 6 French “grabbed a knife and threatened to harm himself.” (Id.) Jordan French called 911 for 7 assistance. (Id.) While on the phone, Curtis French became “more belligerent and aggressive.” 8 (Id.) With the exception of a grandson who was asleep, all family members exited the house and 9 “waited outside for the police to arrive, in hopes they would take Curtis [French] to sober up.” 10 (Id.) 11 “At least six Pierce County Sheriff’s Officers . . . were dispatched to the call.” (Id.) The 12 dispatched officers were told “Curtis [French] was standing on the porch with a knife in hand, 13 that Curtis [French] was extremely intoxicated, and that Curtis [French] was saying he was going 14 to kill himself.” (Id. at 3.) Plaintiff asserts “Officers knew that he was in a fragile mental state.”

15 (Id.) 16 When Officers Aaron Wolfe and Jason Chavez1 (collectively, “Officers”) arrived, “Curtis 17 [French] was still standing on the porch . . . with a knife in his hands.” (Id.) Officers Wolfe and 18 Chavez, while “standing in the middle of the street in front of the house” had their firearms 19 drawn on Curtis French. (Id.) Plaintiff alleges the Officers and the family members were not in 20 immediate danger. (Id.) 21 22

1 The FAC refers to Defendant Jason Chavez as “Officer Sanchez.” Plaintiff acknowledges this 23 error in the Reply to the Motion to Dismiss. Plaintiff shall file a new amended complaint to correct this error. 24 1 Barely able to walk, Curtis French stumbled down the house steps and bumped into a 2 vehicle in the driveway. (Id.) He showed clear signs of intoxication and was holding his hands 3 out to his side. (Id.) When Curtis French “stumbled clumsily in the direction of officers Wolfe 4 and Chavez, they shot him twelve times, within seconds of arriving at the house.” (Id.) “Curtis

5 [French] did not attack, or attempt to attack, the officers.” (Id.) Curtis French died in front of 6 his family. (Id.) Plaintiff alleges the Officers “did not attempt to de-escalate the situation.” (Id.) 7 Less than a minute after firing, the other officers who had been dispatched arrived at the scene. 8 (Id.) 9 Plaintiff’s First Amended Complaint brings 42 U.S.C. § 1983 claims for excessive force 10 and Washington State negligence claims against Pierce County, Officer Aaron Wolfe, and 11 Officer Jason Chavez. Defendants move to dismiss all claims for failure to state a claim. 12 III. DISCUSSION 13 Federal Rule of Civil Procedure 12(b) motions to dismiss may be based on either “the 14 lack of a cognizable legal theory or the absence of sufficient facts alleged under a cognizable

15 legal theory.” Balistreri v. Pacifica Police Department, 901 F.2d 696, 699 (9th Cir. 16 1990). Material allegations are taken as admitted and the complaint is construed in the plaintiff's 17 favor. Keniston v. Roberts, 717 F.2d 1295, 1300 (9th Cir. 1983). “While a complaint attacked 18 by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiff's 19 obligation to provide the grounds of his entitlement to relief requires more than labels and 20 conclusions, and a formulaic recitation of a cause of action’s elements will not do.” Bell Atlantic 21 Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal citations omitted). “Factual allegations 22 must be enough to raise a right to relief above the speculative level on the assumption that all of 23 the complaint’s allegations are true,” even if such allegations are “doubtful in fact.” Id. at 555.

24 1 The complaint must allege “enough facts to state a claim to relief that is plausible on its 2 face.” Id. at 547. 3 A. Excessive Force 4 1. 42 U.S.C. § 1983 Claim against Officers Wolfe and Chavez

5 Plaintiff asserts a 42 U.S.C. § 1983 Fourth Amendment excessive force claim against the 6 Officers. To maintain a claim, Plaintiff must assert facts establishing the Defendants (1) acted 7 under color of state law and (2) violated Curtis French’s civil rights. 42 U.S.C. § 1983. The first 8 element is met as the FAC asserts the Officers are “police officer[s] employed by Pierce County 9 Sherriff’s Department,” and that “[a]ll acts committed by [the Officers] were done under color of 10 state law and within the course and scope of [their] employment with the [Pierce County 11 Sheriff’s Department].” (Dkt. No. 15 at 2.) 12 As to the second element, Fourth Amendment excessive force claims are evaluated under 13 a reasonableness standard that balances “the nature and quality of the intrusion on the 14 individual’s Fourth Amendment interests against the countervailing governmental interests at

15 stake.” Graham v. Connor, 490 U.S. 386, 396 (1989) (internal citations omitted). Proper 16 application of reasonableness “requires careful attention to the facts and circumstances of each 17 particular case, including the severity of the crime at issue, whether the suspect poses an 18 immediate threat to the safety of the officers or others, and whether he is actively resisting arrest 19 or attempting to evade arrest by flight.” Id. These factors are not exhaustive. “In some cases, 20 for example, the availability of alternative methods of capturing or subduing a suspect may be a 21 factor to consider.” Chew v. Gates, 27 F.3d 1432, 1440 n.5 (9th Cir. 1994). 22 a. Immediate Threat to Others 23

24 1 The FAC alleges Curtis French was so drunk he could not walk, let alone coordinate an 2 attack. (Dkt. No. 15 at 2–3.) It also alleges that, although he was standing on the porch with a 3 knife in his hand when the Officers arrived, he stumbled “clumsily in the direction of” the 4 Officers without attacking or attempting to attack the Officers. (Id. at 3.) It further alleges the

5 Officers were standing in the middle of the street (id.), presumably a distance from Curtis 6 French. 7 In Smith v.

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French v. Pierce County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-v-pierce-county-wawd-2023.