Gorman v. Tamaso

CourtDistrict Court, D. Nevada
DecidedMay 2, 2024
Docket2:22-cv-01678
StatusUnknown

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

Bluebook
Gorman v. Tamaso, (D. Nev. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 7 RICKEY LEE GORMAN, Case No. 2:22-cv-01678-JAD-NJK

8 Plaintiff(s), ORDER 9 v. 10 BRITTANY TAMASO, et al., 11 Defendant(s). 12 Plaintiff has filed an amended complaint, Docket No. 18, which the Court screens herein 13 pursuant to 28 U.S.C. § 1915(e)(2). 14 I. STANDARDS 15 Federal courts are given the authority to dismiss a case if the action is legally “frivolous or 16 malicious,” fails to state a claim upon which relief may be granted, or seeks monetary relief from 17 a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). 18 Rule 12(b)(6) of the Federal Rules of Civil Procedure provides for dismissal of a complaint 19 for failure to state a claim upon which relief can be granted. Review under Rule 12(b)(6) is 20 essentially a ruling on a question of law. See Chappel v. Lab. Corp. of Am., 232 F.3d 719, 723 21 (9th Cir. 2000). A properly pled complaint must provide a short and plain statement of the claim 22 showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2); Bell Atlantic Corp. v. 23 Twombly, 550 U.S. 544, 555 (2007). Although Rule 8 does not require detailed factual allegations, 24 it demands “more than labels and conclusions” or a “formulaic recitation of the elements of a cause 25 of action.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Papasan v. Allain, 478 U.S. 265, 26 286 (1986)). The court must accept as true all well-pled factual allegations contained in the 27 complaint, but the same requirement does not apply to legal conclusions. Iqbal, 556 U.S. at 679. 28 Mere recitals of the elements of a cause of action, supported only by conclusory allegations, do 1 not suffice. Id. at 678. Secondly, where the claims in the complaint have not crossed the line from 2 conceivable to plausible, the complaint should be dismissed. Twombly, 550 U.S. at 570. 3 Allegations of a pro se complaint are held to less stringent standards than formal pleadings drafted 4 by lawyers. Hebbe v. Pliler, 627 F.3d 338, 342 & n.7 (9th Cir. 2010) (finding that liberal 5 construction of pro se pleadings is required after Twombly and Iqbal). 6 When a court dismisses a complaint under § 1915, the plaintiff should be given leave to 7 amend the complaint with directions as to curing its deficiencies, unless it is clear from the face of 8 the complaint that the deficiencies could not be cured by amendment. See Cato v. United States, 9 70 F.3d 1103, 1106 (9th Cir. 1995). 10 II. ANALYSIS 11 The amended complaint raises claims against 23 Defendants for alleged improprieties 12 related to Plaintiff’s arrest, transport to jail, interrogation, criminal defense, and prosecution.1 The 13 Court screens the various claims in turn below. 14 A. Grounds for Arrest 15 Plaintiff alleges that he was unlawfully arrested without probable cause. See, e.g., Docket 16 No. 18 at 8 (“The [a]rrest was made without established probable cause”). This claim fails for at 17 least two reasons. 18 First, the Supreme Court has held that a § 1983 action cannot be used to collaterally attack 19 a criminal conviction unless the conviction or sentence has been reversed on direct appeal, 20 expunged by executive order, declared invalid by a state tribunal authorized to make such a 21 determination, or called into question by a federal court’s issuance of a writ of habeas corpus. 22 Heck v. Humphrey, 512 U.S. 477, 484 (1994). In determining whether a claim is barred by Heck, 23 the critical question is whether finding in the plaintiff’s favor on a § 1983 claim would necessarily 24 imply the invalidity of his conviction or sentence. Szajer v. City of Los Angeles, 632 F.3d 607, 25 611 (9th Cir. 2011). There is “no question” that Heck bars claims that officers lacked probable 26

27 1 Plaintiff separates his allegations into three claims. Construing his amended complaint liberally and in an effort to provide clarity, the Court will address his allegations as attempting to 28 bring more than three claims. 1 cause to arrest a criminal suspect. Smithart v. Towery, 79 F.3d 951, 952 (9th Cir. 1996) (per 2 curiam). In this case, Plaintiff was convicted, see, e.g., Docket No. 18 at 16,2 and Plaintiff has not 3 shown that his conviction has been reversed or otherwise called into question. To the contrary, 4 Plaintiff identifies ongoing habeas efforts that have not to date been resolved in his favor, id. 5 (identifying habeas hearing),3 and Plaintiff’s direct appeal was recently rejected by the Court of 6 Appeals of Nevada, Gorman v. State, 540 P.3d 457 (Nev. App. Dec. 28, 2023) (affirming denial 7 of mistrial request that was predicated on the testimony of the victim’s roommate, H. Miller). As 8 a challenge to whether probable cause existed for his arrest calls into question Plaintiff’s 9 conviction, this claim is barred. 10 Second, the complaint does not sufficiently allege a lack of probable cause at any rate. The 11 amended complaint alleges that witness Heather Miller alerted authorities to the alleged crime, 12 was interviewed by the police, and identified Plaintiff in photographic evidence. See Docket No. 13 18 at 14. A witness providing such information to the police can create probable cause for an 14 arrest. See Peng v. Mei Chin Penghu, 335 F.3d 970, 978 (9th Cir. 2003) (explaining that probable 15 cause may be established by a victim’s statements that provide “facts sufficiently detailed to cause 16 a reasonable person to believe a crime had been committed and the named suspect was the 17 perpetrator”); see also Morales v. City of Bellingham, 2020 WL 7714412, at *4 (W.D. Wash. Dec. 18 29, 2020) (addressing foundation for probable cause from statements of a putative victim or 19 eyewitness) (quoting Gramenos v. Jewel Cos., 797 F.2d 432, 439 (7th Cir. 1986)). Plaintiff’s 20 theory of a lack of probable cause appears to hinge on his conclusory assertion that the 21 photographic identification was conducted in a manner that was “impermissibly suggestive.” Id. 22 That type of label or legal conclusion does not suffice to state a claim. E.g., Iqbal, 556 U.S. at 23 678.4 24 2 It appears that Plaintiff may not have been convicted on all charges, but he was convicted. 25 See, e.g., Docket No. 18 at 16 (acknowledging the “single charge that I have been convicted of”). 26 3 Plaintiff alleges that his conviction has been called into question by his seeking habeas relief, but he has not shown that habeas relief has been granted. See, e.g., Docket No. 18 at 16. 27 4 Plaintiff similarly fails to state a claim with respect to the searches conducted incident to 28 his arrest that were allegedly performed without probable cause. See, e.g., Docket No. 18 at 11. 1 Accordingly, Plaintiff has not stated a colorable claim arising out of his allegedly unlawful 2 arrest.5 3 B.

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Gorman v. Tamaso, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gorman-v-tamaso-nvd-2024.