Fulbright v. Hodges

CourtDistrict Court, W.D. North Carolina
DecidedMay 12, 2022
Docket5:22-cv-00026
StatusUnknown

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

Bluebook
Fulbright v. Hodges, (W.D.N.C. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION CIVIL CASE NO. 5:22-cv-00026-MR

WESLEY FULBRIGHT, ) ) Plaintiff, ) ) vs. ) ) FNU HODGES, et al., ) ORDER ) Defendants. ) _______________________________ )

THIS MATTER is before the Court on initial review of the pro se Complaint [Doc. 1]. Also proceeding is the Plaintiff’s Motion for the Appointment of Counsel [Doc. 4]. The Plaintiff is proceeding in forma pauperis. [Doc. 8]. I. BACKGROUND The pro se Plaintiff, who is incarcerated at the Avery Mitchell Correctional Institution, filed this civil rights action pursuant to 42 U.S.C. § 1983.1 He names as Defendants in their official and individual capacities:

1 The Plaintiff is serving a sentence of up to nine years and 10 months’ imprisonment for conspiracy to traffic in a schedule II controlled substance and possession of a firearm by a felon. This information is gleaned in part from the North Carolina Department of Public Safety’s (NCDPS) website. See https://webapps.doc.state.nc.us/opi/viewoffender.do? method=view&offenderID=0600694&searchLastName=fulbright&searchFirstName=wesl ey&searchDOBRange=0&listurl=pagelistoffendersearchresults&listpage=1 (last visited Darren E. Campbell,2 the sheriff of Iredell County; John Doe, the Iredell County manager; and FNU Hodges, FNU Frye, and John Doe, Iredell County

Sheriff’s Office (ICSO) officers. He claims that Officers Hodges, Frye, and John Doe violated the Fourth and Fourteenth Amendments when they arrested him on a misdemeanor warrant in his home on March 10, 2019, and that Frye and, possibly, other unknown officers3 searched his home with a

warrant on March 14, 2019. [Doc. 1 at 5-7]. As injury, the Plaintiff claims “loss of property, loss of liberty, failure of guaranteed security in home from wrongful intrusion.” [Id. at 8]. The Plaintiff seeks a declaratory judgment that

the Defendants violated the Fourth and Fourteenth Amendments.4 [Id.]. II. STANDARD OF REVIEW Because the Plaintiff is proceeding in forma pauperis, the Court must

review the Complaint to determine whether it is subject to dismissal on the grounds that it is “frivolous or malicious [or] fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2). Furthermore, under § 1915A the Court must conduct an initial review and identify and dismiss the

complaint, or any portion of the complaint, if it is frivolous, malicious, or fails

May 2, 2022); Fed. R. Evid. 201. 2 “Name Unknown” in the Complaint. [Doc. 1 at 3].

3 The Plaintiff does not name these unknown officers as Defendants.

4 The Plaintiff does not seek damages or relief from his criminal conviction. [Doc. 1 at 8]. to state a claim upon which relief may be granted; or seeks monetary relief from a defendant who is immune to such relief. 28 U.S.C. § 1915A.

In its frivolity review, this Court must determine whether the Complaint raises an indisputably meritless legal theory or is founded upon clearly baseless factual contentions, such as fantastic or delusional scenarios.

Neitzke v. Williams, 490 U.S. 319, 327-28 (1989). Furthermore, a pro se complaint must be construed liberally. Haines v. Kerner, 404 U.S. 519, 520 (1972). However, the liberal construction requirement will not permit a district court to ignore a clear failure to allege facts in his Complaint which

set forth a claim that is cognizable under federal law. Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990). III. DISCUSSION

To state a claim under § 1983, a plaintiff must allege that he was “deprived of a right secured by the Constitution or laws of the United States, and that the alleged deprivation was committed under color of state law.” Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 49-50 (1999).

The Plaintiff purports to sue the Defendants in their official and individual capacities. A state official can be sued in a § 1983 suit in three ways: in his personal capacity, his official capacity, or in a more limited way,

his supervisory capacity. King v. Rubenstein, 825 F.3d 206, 223–24 (4th Cir. 2016). For personal liability, “it is enough to show that the official, acting under color of state law, caused the deprivation of a federal right.” Kentucky

v. Graham, 473 U.S. 159, 166 (1985). In an official-capacity suit, however, “[m]ore is required”: the suit is “treated as a suit against the entity,” which must then be a “‘moving force’ behind the deprivation,” King, 825 F.3d at 223

(quoting Polk County v. Dodson, 454 U.S. 312, 326 (1981)); thus, the entity’s “‘policy or custom’ must have played a part in the violation of federal law,” id. (quoting Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658, 694 (1978)). Meanwhile, a supervisor can be liable where (1) he knew that

his subordinate “was engaged in conduct that posed a pervasive and unreasonable risk of constitutional injury;” (2) his response showed “deliberate indifference to or tacit authorization of the alleged offensive

practices;” and (3) that there was an “affirmative causal link” between his inaction and the constitutional injury.” Shaw v. Stroud, 13 F.3d 791, 799 (4th Cir. 1994) (internal quotation marks omitted). The Plaintiff claims that the Sheriff and the County Manager “are

directly responsible for the training and oversight of its officers, and are partially responsible for the actions if the actions are deemed violative of the law of the State and the United States.” [Doc. 1 at 8]. He does not allege

that Sheriff Campbell and County Manager John Doe were personally involved in the alleged violations of his rights, and therefore, he has failed to state a claim against them in their individual capacities. See Vinnedge v.

Gibbs, 550 F.2d 926, 928 (4th Cir. 1977) (to establish individual capacity liability under 42 U.S.C. § 1983, a plaintiff must show that the defendants “acted personally” to cause the alleged violation). The allegations about

training and oversight are too vague and conclusory to establish official- capacity or supervisory liability by Sheriff Campbell and County Manager John Doe. Rather, this claim appears to be based on respondeat superior, which does not apply in actions brought under § 1983. See Monell, 436 U.S.

at 694. Accordingly the claims against Sheriff Campbell and County Manager John Doe are dismissed without prejudice. The Plaintiff’s official-capacity claims against Defendants Hodges,

Frye, and Officer John Doe are, in substance, claims against the office of the sheriff itself. Gannt v. Whitaker, 203 F.Supp.2d 503, 508 (M.D.N.C. Feb. 26, 2002). However, the Plaintiff has failed to allege that a sheriff’s office policy or custom played a role in the alleged violation of the Plaintiff’s rights.

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Fulbright v. Hodges, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fulbright-v-hodges-ncwd-2022.