French v. Schofftall

CourtDistrict Court, D. Idaho
DecidedJanuary 23, 2025
Docket2:23-cv-00545
StatusUnknown

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

Bluebook
French v. Schofftall, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

WALTER TODD FRENCH, Case No.: 2:23-cv-00545-BLW-REP

Plaintiff, REPORT AND RECOMMENDATION RE: vs. DEFENDANT STATE OF IDAHO’S JULIA C. SCHOFFSTALL; WES SOMERTON; MOTION TO DISMISS MATT SIMMONS; KOOTENAI COUNTY (Dkt. 7) SHERIFF’S DEPARTMENT, THE STATE OF IDAHO, THE KOOTENAI COUNTY DEFENDANTS’ RULE 12(b)(6) Defendants, MOTION TO DISMISS (Dkt. 16)

and

MEMORANDUM DECISION AND ORDER RE:

PLAINTIFF’S MOTION FOR APPOINTMENT OF COUNSEL (Dkt. 19)

Pending before the Court are (i) Defendant State of Idaho’s Motion to Dismiss (Dkt. 7); (ii) the Kootenai County Defendants’ Rule 12(b)(6) Motion to Dismiss (Dkt. 16); and (iii) Plaintiff’s Motion for Appointment of Counsel (Dkt. 19). For the reasons that follow, Plaintiff’s claims against Defendants are without merit. The undersigned therefore recommends that Defendants’ Motions to Dismiss be granted. Moreover, the undersigned hereby orders that Plaintiff’s Motion for Appointment of Counsel is denied.1

1 This action was originally assigned to the undersigned on December 4, 2023. However, when the parties did not consent to magistrate judge jurisdiction, the action was reassigned to U.S. District Judge B. Lynn Winmill on September 4, 2024. Judge Winmill referred the action back to the undersigned the next day. See Order Referring Case (Dkt. 28) (instructing the undersigned to enter (i) orders on non-dispositive matters and (ii) reports and recommendations on dispositive matters). I. BACKGROUND Plaintiff Walter Todd French was arrested and charged with committing a battery upon his sister-in-law after the Coeur d’Alene Police Department responded to a reported disturbance at the sister-in-law’s house on November 15, 2022. See Compl. at 4 (Dkt. 1). Plaintiff alleges various injustices related to his arrest and the circumstances surrounding his subsequent

prosecution in Idaho state court. He in turn brings this action against the State of Idaho and multiple Kootenai County officials (including the Kootenai County Sheriff’s Department),2 requesting that (i) all charges against him be vacated; (ii) he be awarded $25 million in punitive damages, plus an additional $1 million for every hour spent in jail after being bonded out (totaling $2.5 million); (iii) the individuals associated with his prosecution face criminal charges and disbarment; and (iv) his sister-in-law face felony charges for violating 42 U.S.C. § 1030a-7a (using a medical facility to illicit a decision and falsify medical records). Id. at 3-4. The two sets of Defendants – the State of Idaho and the Kootenai County Defendants – move to dismiss Plaintiff’s claims. The State of Idaho preliminarily argues that it is immune

from suit under the Eleventh Amendment and therefore moves to dismiss Plaintiff’s claims for lack of subject-matter jurisdiction under Rule 12(b)(1). See Mem. ISO MTD at 2-6 (Dkt. 7-1). It separately argues that it is not a “person” under § 1983 and therefore moves to dismiss Plaintiff’s claims for failure to state a claim under Rule 12(b)(6). See id. at 6-7. The Kootenai County Defendants also argue that Plaintiff’s Complaint must be dismissed under Rule 12(b)(6)

2 As the basis for the Court’s jurisdiction (federal question), Plaintiff lists the following claims: “Bias, Malicious Prosecution, Prosecutorial Misconduct, Cruel and Unusual Punishment, Wrongful Imprisonment, Intentional Infliction of Emotional Distress, Aiding and Abetting a Criminal Enterprise, Conspiracy to Commit Fraud, Criminal Impersonation, Abuse of Power, Impeding the Function of Law, Using a Legal Document as an Instrument to Perpetrate a Fraud, Mail Fraud, Wire Fraud, Felony Intimidation, Felony Retaliation, Bias based on my Genetic Makeup (I’m a 6’3”, 240lb HIV + Gay Man), Bias based on Michele French [(Plaintiff’s sister- in-law)] being a Female (5’10”, 200+lbs), Falsifying Medical Records.” Compl. at 3 (Dkt. 1). for failure to state a cognizable claim against certain of them. See Mem. ISO MTD at 3-4 (Dkt. 16-1). They further argue that leave to amend would be futile because Plaintiff’s claims are barred by Heck v. Humphrey, 512 U.S. 477 (1994), the Defendant prosecutors are entitled to absolute immunity, and Plaintiff cannot show municipal liability against Kootenai County itself. See id. at 4-9.3 Each of these arguments is addressed below.

II. LEGAL STANDARDS A. Motion to Dismiss: Rule 12(b)(1) “Federal courts are courts of limited jurisdiction and are presumptively without jurisdiction over civil actions.” Howard Jarvis Taxpayers Ass’n v. Cal. Secure Choice Ret. Sav. Program, 443 F. Supp. 3d 1152, 1156 (E.D. Cal. 2020) (citing Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377 (1994)). Federal courts “possess only that power authorized by Constitution and statute, which is not to be expanded by judicial decree.” Kokkonen, 511 U.S. at 377. Subject-matter jurisdiction is required; it cannot be forfeited or waived. Howard Jarvis Taxpayers Ass’n, 443 F. Supp. 3d at 1156. Indeed, “[i]f the court determines at any time that it

lacks subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3). Rule 12(b)(1) provides that a party may challenge a federal court’s jurisdiction over the subject-matter of the complaint. A Rule 12(b)(1) jurisdictional attack may be factual or facial.

3 “A motion asserting [a defense of failure to state a claim upon which relief can be granted] must be made before pleading if a responsive pleading is allowed.” Fed. R. Civ. P. 12(b). But here, the Kootenai County Defendants moved to dismiss Plaintiff’s claims after they filed their Answer. Compare Ans. (Dkt. 14), with MTD (Dkt. 16). The Court can still treat the Motion to Dismiss as one for judgment on the pleadings pursuant to Rule 12(c). Aldabe v. Aldabe, 616 F.2d 1089, 1093 (9th Cir. 1980); see also Fed. R. Civ. P. 12(h)(2) (authorizing a motion under Rule 12(c) to raise the defense of failure to state a claim, even after the answer has been filed). Importantly, the legal standard for Rule 12(c) is “substantially identical” to the standard for Rule 12(b)(6) because under both Rules, “a court must determine whether the facts alleged in the complaint, taken as true, entitle the plaintiff to a legal remedy.” Chavez v. United States, 683 F.3d 1102, 1108 (9th Cir. 2012). Given this congruity, the Court will consider the arguments raised within the Kootenai County Defendants’ Motion to Dismiss. White v. Lee, 227 F.3d 1214, 1242 (9th Cir. 2000). A factual attack presents extrinsic evidence disputing the truth of the allegations of the complaint that would otherwise invoke federal jurisdiction, whereas a facial attack challenges that the allegations contained in the complaint are insufficient on their face to invoke federal jurisdiction. Wolfe v. Strankman, 392 F.3d 358, 362 (9th Cir. 2004).

Here, the State of Idaho’s Motion to Dismiss under Rule 12(b)(1) mounts a facial challenge: it contends that, notwithstanding Plaintiff’s allegations, the Eleventh Amendment bars Plaintiff’s suit against it. See Mem. ISO MTD at 3-6 (Dkt.

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French v. Schofftall, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-v-schofftall-idd-2025.