Griffin v. Garcia

CourtDistrict Court, E.D. Wisconsin
DecidedMay 8, 2025
Docket2:19-cv-01070
StatusUnknown

This text of Griffin v. Garcia (Griffin v. Garcia) 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
Griffin v. Garcia, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

RAVEN GRIFFIN,

Plaintiff,

v. Case No. 19-cv-1070-pp

EDUARDO GARCIA,

Defendant.

ORDER GRANTING DEFENDANT’S MOTION TO DISMISS (DKT. NO. 12), DISMISSING COMPLAINT WITHOUT PREJUDICE AND ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT

On July 25, 2019, the plaintiff—representing herself—filed a complaint alleging, among other things, false arrest and false imprisonment claims arising out of a July 2016 arrest by the Milwaukee Police Department. Dkt. No. 1. The court screened the complaint and allowed the plaintiff to proceed only on her false arrest and false imprisonment claims against police officer Eduardo Garcia. Dkt. No. 6 at 27. On April 26, 2024, the defendant filed a motion to dismiss the complaint. Dkt. No. 12. The court will grant the motion and allow the plaintiff to file an amended complaint. I. The Complaint As described in the court’s screening order, this is one of five cases the plaintiff filed in this district relating to her July 7, 2016 arrest and subsequent prosecution for robbery. Dkt. No. 6 at 1–2 (describing plaintiff’s prior cases). The complaint alleges that on July 7, 2016, the plaintiff called 911 due to her landlord’s parents allegedly trespassing by entering her home and refusing to leave. Dkt. No. 1 at 2. The plaintiff alleges that they were attempting to evict her. Id. She alleges that after they attacked her, she drove to the police station

to report the incident. Id. at 2–3. The plaintiff alleges that when she arrived at the police station, the desk sergeant, Officer Cook, told her that the defendant instructed him to place the plaintiff under arrest. Id. at 3. The plaintiff alleges that she objected but that Cook detained her in the police station and handcuffed her to a hard bench. Id. The plaintiff, who was pregnant at the time, says she told Cook that she needed medical attention. Id. The plaintiff alleges that Cook told her that she needed to wait for the defendant. Id.

When the defendant and another officer, Officer Muller, arrived, the plaintiff alleges that “he” told her she was being charged with battery, robbery and disorderly conduct. Id. at 3–4. The plaintiff alleges that “he” then told her that “the daughter had ties within the police department.” Id. at 4. The plaintiff does not identify whether the defendant or Muller made these statements. The plaintiff alleges that “[a]fter 30 to 45 minutes of insulting me,” “he” took the plaintiff to the hospital, where she was handcuffed to the bed. Id. Again, the

plaintiff does not state who took her to the hospital. The plaintiff alleges that she suffered a miscarriage in the hospital. Id. The plaintiff alleges that afterward, she was taken to the Milwaukee County Jail, where she was jailed for four days. Id. She alleges that all the charges were dropped on July 12, 2016, except that she was later re-charged with one count of robbery. Id. The court dismissed all claims and defendants except the plaintiff’s claims for false arrest and false imprisonment against Garcia. Dkt. No. 6. The

court construed the complaint as alleging these claims under 42 U.S.C. §1983. Id. at 9, 11. The court limited the plaintiff’s false imprisonment claim to the allegations that the defendant held her at the police station and at the hospital, but the court did not allow the plaintiff to proceed with a false imprisonment claim arising out of her four days in jail because the complaint did not allege that the defendant took her to the jail or ordered her to be held there. Id. at 11– 12. II. Legal Standard

Federal Rule of Civil Procedure 12(b)(6) allows a party to assert by motion that the complaint fails to state a claim upon which a federal court can grant relief. “A Rule 12(b)(6) motion tests ‘the legal sufficiency of the complaint,’ as measured against the standards of Rule 8(a).” Gunn v. Cont’l Cas. Co., 968 F.3d 802, 806 (7th Cir. 2020) (quoting Runnion ex rel. Runnion v. Girl Scouts of Greater Chi. & Nw. Ind., 786 F.3d 510, 526 (7th Cir. 2015)). A complaint need not include detailed factual allegations, but it must “state a claim to relief

that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if it “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) (citing Twombly, 550 U.S. at 556). In ruling on a Rule 12(b)(6) motion, the court takes “all the factual allegations in the complaint as true,” Ashcroft v. Iqbal, 556 U.S. 662 (2009), and draws all reasonable inferences in the plaintiff’s favor, Roberts v. City of Chicago, 817 F.3d 561, 564 (7th Cir. 2016).

III. Motion to Dismiss The defendant filed a motion to dismiss the complaint, arguing that it fails to state a claim upon which relief can be granted, that the defendant had probable cause to arrest the plaintiff and that the defendant is entitled to qualified immunity. Dkt. No. 12. A. Parties’ Arguments The defendant argues that the plaintiff failed to provide enough facts to state a claim that the defendant violated her constitutional rights. Id. at 2. He

argues that the complaint is unclear as to which of the three officers who were present threatened the plaintiff with charges, insulted her and took her to receive medical attention. Id. at 4. The defendant argues that because it is not clear whether the defendant is the one that made those statements, the complaint is too vague to state a claim. Id. The defendant contends that even if the court does not dismiss the complaint for vagueness, it should dismiss the complaint because the

defendant had probable cause to arrest the plaintiff. Id. at 4. The defendant asserts that probable cause is “an absolute defense to any claim against police officers for false imprisonment and wrongful arrest.” Id. at 5 (citing Mustafa v. City of Chicago, 442 F.3d 544, 547 (7th Cir. 2006)). The defendant attached to his motion the police report related to this incident, which the defendant asserts the court can consider on a motion to dismiss because it is referred to in the plaintiff’s complaint and is central to her claim. Id. at 6 (quoting Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429, 431 (7th Cir. 1993)).

The defendant argues that the report is “central” to the claim because it is “critical” to determining whether the defendant had probable cause at the time of the plaintiff’s arrest. Id. The defendant says that after the plaintiff reported the July 7, 2016 trespassing incident to the police department by phone, police officers— including the defendant—responded to the plaintiff’s residence. Id. at 7. The plaintiff was not present, because she had driven to the police station to report the incident in person. Id. The defendant states that according to the police

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Griffin v. Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griffin-v-garcia-wied-2025.