Genskow v. Prevost

CourtDistrict Court, E.D. Wisconsin
DecidedApril 6, 2020
Docket1:19-cv-01474
StatusUnknown

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

Bluebook
Genskow v. Prevost, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

MADELYN P. GENSKOW,

Plaintiff,

v. Case No. 19-C-1474

STACEY PREVOST, et al.,

Defendants.

DECISION AND ORDER GRANTING MOTION TO DISMISS

Plaintiff Madelyn P. Genskow filed this pro se action against Defendants Stacey Prevost, Nate Ness, Eddie Metoxen, and Brandon Van de Hei—each an officer of the Oneida Nation’s police department—claiming that the defendants unreasonably and with excessive force removed Genskow from the meeting of the General Tribal Council of the Oneida Nation which was held at the Radisson Hotel on July 10, 2018. Presently before the court is the defendants’ motion to dismiss (Dkt. No. 17) and Genskow’s motion to add a defendant to her action (Dkt. No. 24). For the reasons that follow, the defendants’ motion to dismiss will be granted and Genskow’s motion to add a defendant will be denied. LEGAL STANDARD The defendants have moved to dismiss this action under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. A Rule 12(b)(1) motion challenges the jurisdiction of this court over the subject matter related in the complaint. Fed. R. Civ. P. 12(b)(1). In this case, the defendants contend that the court lacks subject matter jurisdiction because Genskow’s claims are barred under the doctrine of sovereign immunity. The question of sovereign immunity, however, is not jurisdictional. Meyers v. Oneida Tribe of Indians of Wisconsin, 836 F.3d 818, 820 (7th Cir. 2016). Nevertheless, because a plaintiff’s otherwise valid claims may be barred under the doctrine of sovereign immunity, the defense can be appropriately asserted in a motion to dismiss under Rule 12(b)(6). Id. A Rule 12(b)(6) motion tests the sufficiency of the complaint to state a claim upon which relief can be granted. Gibson v. City of Chicago, 910 F.2d 1510, 1520 (7th Cir. 1990); see Fed. R. Civ. P. 12(b)(6). When reviewing a motion to dismiss under Rule 12(b)(6), the court must accept all well-pleaded factual allegations as true and draw all reasonable inferences in the light most favorable to the nonmoving party. Gutierrez v. Peters, 111 F.3d 1364, 1368–69 (7th Cir. 1997); Mosley v. Klincar, 947 F.2d 1338, 1339 (7th Cir. 1991). Rule 8 mandates that a complaint need only include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The plaintiff’s short and plain statement must “give the defendant

fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). While a plaintiff is not required to plead detailed factual allegations, he must plead “more than labels and conclusions.” Id. A simple, “formulaic recitation of the elements of a cause of action will not do.” Id. A claim is plausible on its face 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, 663 (2009). ALLEGATIONS OF THE COMPLAINT Genskow is a 77-year-old elder of the Oneida Nation, a federally recognized Indian tribe. See 83 Fed. Reg. 4235, 5238 (Jan. 30, 2018). She claims that the defendants, employees of the

Oneida Nation and officers of the Oneida Police Department, used excessive force and harassed, intimidated, and embarrassed her when they removed her from a conference room at the Radisson 2 Hotel, a tribal building located on tribal land, in front of 1,500 tribal members during a General Tribal Council meeting held on July 10, 2018. Dkt. No. 1 at 3–4. During the meeting, Genskow says her microphone was silenced after she raised continuous calls for “Point of Order” because the Tribal Chairman refused to recognize her. The Chairman then directed the defendants to physically remove her from the meeting. Genskow alleges that the defendants each grabbed one of her limbs, carried her out of the room, and placed her outside the hotel. Id. at 3. Genskow claims she sustained a personal injury requiring medical treatment during the removal, and also suffered humiliation and damage to her reputation. She alleges Defendant Prevost issued her three “bogus citations” for violations of the law, including one criminal citation. She claims these “sham charges” were dropped by the Brown County District Attorney after reviewing the General Tribal Council’s meeting footage and body camera video captured by the defendants. Genskow seeks an award of $4 million, in addition to punitive damages and

$5,000 in reimbursement for attorney’s fees and court costs incurred in relation to the “spurious criminal citations that were intended to harass and intimidate the Plaintiff.” She also requests an order barring the Oneida Police Department from issuing “bogus trespassing citations to federally- enrolled tribal members as a harassment tool” at General Tribal Council meetings. Id. at 4. ANALYSIS A. Sovereign Immunity The defendants argue that the court must dismiss Genskow’s action because it is barred under the doctrine of sovereign immunity and for failure to state a federal claim. Turning first to the threshold issue of sovereign immunity, the starting point is the principle that “Indian tribes are

domestic dependent nations that exercise inherent sovereign authority.” Michigan v. Bay Mills Indian Comty., 572 U.S. 782, 788 (2014) (internal quotations omitted). Among the core aspects 3 of sovereignty that tribes possess is the common-law immunity from suit traditionally enjoyed by sovereign powers. Id. The interests served by the doctrine of tribal sovereign immunity are at their highest when a tribe exercises tribal authority over its own members on its own land. Indian tribes retain “‘their original natural rights’ in matters of local self-government.” Santa Clara Pueblo v. Martinez, 436 U.S. 49, 55 (1978) (quoting Worcester v. Georgia, 6 Pet. 515, 559 (1832)). “Although no longer ‘possessed of the full attributes of sovereignty,’ they remain a ‘separate people, with the power of regulating their internal and social relations.’” Id. (quoting United States v. Kagama, 118 U.S. 375, 381–82 (1886)). “They have power to make their own substantive law in internal matters . . . and to enforce that law in their own forums.” Id. at 55–56 (internal citations omitted). In addition, tribal officers are also immune from suit when they act within their official capacity and within the scope of their authority. Id. at 59. Genskow argues that the Tribal Chairman had no authority to remove her from the General

Tribal Council Meeting when it was in session. When in session, she contends, the General Tribal Council is the governing body of the Tribe and only the Council can remove a tribal member.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Worcester v. Georgia
31 U.S. 515 (Supreme Court, 1832)
United States v. Kagama
118 U.S. 375 (Supreme Court, 1886)
Santa Clara Pueblo v. Martinez
436 U.S. 49 (Supreme Court, 1978)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
White Mountain Apache Tribe v. Bracker
448 U.S. 136 (Supreme Court, 1980)
Montana v. United States
450 U.S. 544 (Supreme Court, 1981)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Hafer v. Melo
502 U.S. 21 (Supreme Court, 1991)
Nevada v. Hicks
533 U.S. 353 (Supreme Court, 2001)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Bressi v. Ford
575 F.3d 891 (Ninth Circuit, 2009)
Michigan v. Bay Mills Indian Community
134 S. Ct. 2024 (Supreme Court, 2014)
Jeremy Meyers v. Oneida Tribe of Indians of Wi
836 F.3d 818 (Seventh Circuit, 2016)
Jocelyn Chatham v. Randy Davis
839 F.3d 679 (Seventh Circuit, 2016)
Gutierrez v. Peters
111 F.3d 1364 (Seventh Circuit, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Genskow v. Prevost, Counsel Stack Legal Research, https://law.counselstack.com/opinion/genskow-v-prevost-wied-2020.