Garrett v. Harris County Sheriff's Office

CourtDistrict Court, S.D. Texas
DecidedFebruary 11, 2025
Docket4:24-cv-02591
StatusUnknown

This text of Garrett v. Harris County Sheriff's Office (Garrett v. Harris County Sheriff's Office) 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
Garrett v. Harris County Sheriff's Office, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT February 11, 2025 Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

DANIEL LEE GARRETT, § § Plaintiff, § § v. § CIVIL ACTION NO. 4:24-cv-2591 § HARRIS COUNTY SHERIFF’S § OFFICE, HARRIS COUNTY § JAIL, AND HARRIS COUNTY, § TEXAS, § § Defendants. §

MEMORANDUM OPINION

Pending before the Court1 is pro se Plaintiff Daniel Lee Garrett’s (“Plaintiff”) Sealed Motion (ECF No. 18), Defendants Harris County Sheriff’s Office, Harris County Jail, and Harris County’s (collectively, “Defendants”) Motion to Dismiss (ECF No. 19), Plaintiff’s Motion to Seal Reply to Motion (ECF No. 21), and Plaintiff’s Motion to Supplement Original Pleading (ECF No. 23). Based on a review of the motions, arguments, and relevant law, the Court GRANTS Defendants’ Motion to Dismiss (ECF No. 19) and DENIES AS MOOT all other pending motions (ECF Nos. 18, 21, 23). Plaintiff’s Amended Complaint (ECF No. 10) is DISMISSED WITH PREJUDICE.

1 The parties consented to proceed before a Magistrate Judge for all proceedings under 28 U.S.C. § 636(c). (ECF No. 24). I. Background2 Plaintiff alleges he was arrested on September 15, 2020, while having a

mental health crisis. (ECF No. 10 at 4). Plaintiff states he was taken to Harris County Jail where he informed medical staff that he was a veteran and needed to go to the hospital. (Id.). After being released from Harris County Jail, Plaintiff alleges he was found running naked along Interstate 10. (Id.).

Plaintiff states he was taken to Lyndon B. Johnson Hospital and released without treatment. (Id.). On June 13, 2024, Plaintiff filed his first complaint and supplemental complaint. (ECF Nos. 2–3). On July 18, 2024, Plaintiff filed an amended

complaint pursuant to 42 U.S.C. § 1983, alleging Fourth, Fifth, Sixth, Eighth, and Fourteenth Amendment violations as well as medical negligence and malpractice claims. (ECF No. 10 at 1). On September 5, 2024, Defendants filed the instant Motion to Dismiss. (ECF No. 19).

II. Legal Standard Federal Rule of Civil Procedure (“Rule”) 12(b)(6) provides for dismissal of an action for “failure to state a claim upon which relief can be granted.” FED. R. CIV. P. 12(b)(6). When considering a motion to dismiss, a court should

2 “When considering a motion to dismiss, the court accepts as true the well-pled factual allegations in the complaint, and construes them in the light most favorable to the plaintiff.” Taylor v. Books A Million, Inc., 296 F.3d 376, 378 (5th Cir. 2002). 2 construe the allegations in the complaint favorably to the pleader and accept as true all well-pleaded facts. Sullivan v. Leor Energy, LLC, 600 F.3d 542, 546

(5th Cir. 2010). In the Fifth Circuit, motions to dismiss under Rule 12(b)(6) are viewed with disfavor and rarely granted. Lormand v. U.S. Unwired, Inc., 565 F.3d 228, 232 (5th Cir. 2009). To survive dismissal, a complaint must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl.

Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

However, a court is not bound to accept legal conclusions couched as factual allegations. Papasan v. Allain, 478 U.S. 265, 286 (1986). Although all reasonable inferences will be resolved in favor of a plaintiff, a plaintiff must plead “specific facts, not mere conclusory allegations.” Tuchman v. DSC

Commc’ns Corp., 14 F.3d 1061, 1067 (5th Cir. 1994); see also Firefighters’ Ret. Sys. v. Grant Thornton, L.L.P., 894 F.3d 665, 669 (5th Cir. 2018) (“Although a complaint does not need detailed factual allegations, the allegations must be enough to raise a right to relief above the speculative level . . . .”) (internal

quotations omitted)). “‘Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.’” Firefighters’ Ret.

3 Sys., 894 F.3d at 669 (quoting Iqbal, 556 U.S. at 678). “The court is not required to conjure up unpled allegations or construe elaborately arcane

scripts to save a complaint.” Santerre v. Agip Petroleum Co., Inc., 45 F. Supp. 2d 558, 568 (S.D. Tex. 1999) (internal quotations omitted). To determine whether to grant a Rule 12(b)(6) motion, a court may only look to allegations in a complaint to determine their sufficiency. Id.; Atwater

Partners of Tex. LLC v. AT & T, Inc., No. 2:10-cv-175-TJW, 2011 WL 1004880, at *1 (E.D. Tex. Mar. 18, 2011). “A court may, however, also consider matters outside the four corners of a complaint if they are incorporated by reference, items subject to judicial notice, matters of public record, orders, items

appearing in the record of a case, and exhibits attached to a complaint whose authenticity is unquestioned.” Joubert on Behalf of Joubert v. City of Houston, No. 4:22-cv-3750, 2024 WL 1560015, at *2 (S.D. Tex. Apr. 10, 2024). “A document filed pro se is to be liberally construed, and a pro se

complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal citations and quotation marks omitted); see also FED. R. CIV. P. 8(e) (“Pleadings must be construed so as to do justice”).

4 III. Discussion Defendants argue all of Plaintiff’s claims fail as a matter of law. (ECF

No. 19 at 3). a. Harris County Jail and Harris County Sheriff’s Office As an initial matter, Defendants argue the Harris County Jail and the Harris County Sheriff’s Office cannot be sued. (Id. at 4).

Under Rule 17(b), an entity must have the capacity to be sued. Thus, for a plaintiff to sue a city or county department, that department must enjoy a separate legal existence. See Darby v. Pasadena Police Dep’t, 939 F.2d 311, 313 (5th Cir. 1991). Whether an entity enjoys a separate legal existence and,

therefore, has the capacity “to sue or be sued is determined . . . by the law of the state where the court is located.” FED. R. CIV. P. 17(b). It is well-settled that “the Harris County Sheriff’s Office is merely an agency or division of Harris County” and does not enjoy a separate legal

existence. Gragert v. Harris Cnty., No. 4:09-cv-2063, 2010 WL 11538411, at *4 (S.D. Tex. Aug. 11, 2010); see also Kennard v. City of Houston, No. 22-cv-3365, 2023 WL 159782, at *2 (S.D. Tex. Jan. 11, 2023), appeal dismissed, No. 23- 20046, 2023 WL 5125068 (5th Cir. Apr. 3, 2023). The same goes for the Harris

County Jail. Hatton v. Harris Cnty. Jail, No. 18-cv-1948, 2019 WL 1858826, at *2 (S.D. Tex. Apr. 25, 2019) (citing Patterson v. Harris Cnty. Jail, No. 09-cv-

5 1516, 2009 WL 10705736, at *3 (S.D. Tex. May 29, 2009), aff’d, 358 F. App’x. 491 (5th Cir. 2009) (“As a division within the Harris County Sheriff’s

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Papasan v. Allain
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Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
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