Hay v. Kruger

CourtDistrict Court, D. Nevada
DecidedMarch 21, 2024
Docket3:22-cv-00321
StatusUnknown

This text of Hay v. Kruger (Hay v. Kruger) 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
Hay v. Kruger, (D. Nev. 2024).

Opinion

6 UNITED STATES DISTRICT COURT

7 DISTRICT OF NEVADA

8 * * *

9 JOEL WALKER HAY, Case No. 3:22-cv-00321-LRH-CSD

10 Plaintiff, ORDER

11 v.

12 JOEL KRUGER, individually and in his official capacity as a DOUGLAS COUNTY 13 DEPUTY SHERIFF; DANIEL COVERLEY, individually and in his official capacity as 14 DOUGLAS COUNTY SHERIFF; DOUGLAS COUNTY, a political subdivision 15 of the State of Nevada; and DOES 1-10, inclusive, 16 Defendants. 17 18 Defendants Douglas County (individually, the “County”), Douglas County Sheriff Daniel 19 Coverley (individually, the “Sheriff”), and Douglas County Deputy Sheriff Joel Kruger 20 (individually, the “Deputy”) (collectively, “Defendants”) move the Court to grant summary 21 judgment in their favor (ECF No. 22) as to Plaintiff Joel Walker Hay’s (“Hay”) complaint (ECF 22 No. 1). Hay opposed (ECF No. 29) and Defendants replied (ECF No. 33). Hay moves the Court to 23 grant partial summary judgment in his favor. ECF No. 20. Defendants opposed (ECF No. 28) and 24 Hay replied (ECF No. 32). Lastly, Hay requests that the Court issue an order permitting him to file 25 his motion for partial summary judgment under seal. ECF No. 19. For the reasons contained within 26 this Order, the Court denies Hay’s motion for partial summary judgment (ECF No. 20), denies 27 Hay’s motion to seal (ECF No. 19), and grants Defendants’ motion for summary judgment (ECF 1 I. BACKGROUND 2 There are no genuine issues of material facts between the parties as to the following 3 information. On August 3, 2020, Hay’s spouse used her cellphone to place an emergency 911 call 4 handled by the Douglas County Sheriff’s Office. ECF No. 22-1 at 2–8. At the time, she was a 5 passenger in a vehicle being driven by Hay, approaching Minden, Nevada, from the north on 6 Highway 395. Id. at 29. During the phone call, Hay’s spouse reported that Hay was intoxicated 7 and had smoked marijuana before he began driving the vehicle; she also reported that he would 8 not stop. Id. at 5. Dispatch tracked the cellphone Hay’s spouse used to place the call, and the 9 Deputy discovered her in a vehicle parked in a business parking lot. Id. With respect to the incident 10 itself, the Deputy and the other responding deputies were investigating both a verbal domestic 11 dispute and a Driving Under the Influence (“DUI”) incident based upon the eyewitness information 12 provided by Hay’s spouse. Id. at 12, 13. When the Deputy arrived on scene with the other 13 responding deputies, Hay’s spouse waived the Deputy down from inside the parked vehicle. Id. at 14 11, 12. She directed the Deputy to the interior of the business office and stated that Hay was inside. 15 Id. at 12. 16 The Deputy entered the business office, and asked Hay to step outside through a rear door 17 to the office. Id. at 13. During a deposition, Hay testified that he had been in the office for less 18 than 15 minutes when the Deputy approached him. Id. at 28. At his deposition, the Deputy testified 19 that, while interacting with Hay in the parking lot, he smelled the distinct odor of alcohol when 20 Hay spoke. Id. at 6, 16. During this interaction, Hay admitted to having consumed three margaritas 21 and having smoked marijuana prior to driving straight from lunch in Reno, Nevada, to Minden. Id. 22 When the Deputy then asked Hay to perform standardized field sobriety tests, he refused. Id. at 23 22–24. After initially refusing, Hay eventually performed a Preliminary Breath Test (“PBT”) after 24 the Deputy explained to him that Nevada’s implied consent statute, i.e., NRS § 484C.150, required 25 Hay to submit to performing a PBT under the circumstances.1 Id. at 23, 24. 26 27 1 1 Hay’s PBT resulted in a blood alcohol content of 0.131. Id. at 33. Hay was subsequently 2 arrested for DUI and transported to the Minden Jail to begin the booking process. Id. at 20, 21. 3 When Hay was asked to submit to an evidentiary blood test following his arrest, he refused. Id. at 4 39. After the Deputy attained a warrant to obtain a blood sample from Hay, the results of the blood 5 test showed that Hay’s blood alcohol content was 0.139. Id. at 47–52. Hay was issued a citation 6 for DUI and released on bail. Id. at 32, 54. The Douglas County District Attorney’s Office 7 subsequently charged Hay with DUI in violation of NRS § 484C.110(1) and Douglas County Code 8 §10.04.030. Id. at 57, 58. On May 5, 2021, pursuant to a negotiated plea agreement, Hay pled no 9 contest to a lesser charge of Reckless Driving in violation of NRS § 484B.653.3(a) and Douglas 10 County Code §10.04.030. Id. at 60–63. A $900 fine was imposed, and Hay was ordered to attend 11 a victim impact panel. Id. at 35, 36, 62, 63. 12 In July of 2022, Hay commenced this action against Defendants. ECF No. 1. In the 13 complaint, Hay asserted the following eight causes of action: (1) unlawful seizure under 42 U.S.C. 14 § 1983 (“§ 1983”) against Defendants; (2) malicious prosecution under § 1983 against Defendants; 15 (3) municipal liability, i.e., a “Monell” claim, based upon failure to train against the County and 16 the Sheriff; (4) conspiracy against Defendants; (5) false arrest, abuse of process, and malicious 17 prosecution under Nevada law against Defendants; (6) intentional infliction of emotional distress 18 (“IIED”) under Nevada law against Defendants; (7) “declaratory relief” against Defendants; and 19 (8) “due process” against Defendants.2 Id. 20 2 Under the eighth cause of action, Hay claims that Defendants violated his “rights to due process of 21 law guaranteed by the Fourteenth Amendment to the United States Constitution and Article I, Section 8 of the” Nevada Constitution. ECF No. 1 at ¶ 79. Because Nevada’s constitutional due 22 process clause mirrors its federal equivalent under the United States Constitution, Nevada courts 23 look to federal authority for guidance when interpreting Nevada’s due process clause. Reinkemeyer v. Safeco Ins. Co., 117 Nev. 44, 50 (Nev. 2001); see also State v. Eighth Judicial Dist. Court, 129 24 Nev. 492, 504 (Nev. 2013). Similarly, United States District Courts for the District of Nevada rely solely on federal case law governing the Fourteenth Amendment when addressing a plaintiff’s 25 claim alleging a deprivation of due process in violation of both the Fourteenth Amendment and Article 1, Section 8 of the Nevada Constitution. See Lopez v. Homan, No. 3:19-cv-00098-RCJ- 26 WGC, 2019 WL 13248856, at *3–6 (D. Nev. July 8, 2019); Williams v. Turner, No. 2:09-cv-01979- KJD-GWF, 2012 WL 273146, at * (D. Nev. Jan. 30, 2012). Hay does not argue that the standards 27 for stating a claim under the Fourteenth Amendment and Article 1, Section 8 of the Nevada 1 On August 11, 2023, Hay filed a motion for partial summary judgment and a motion to file 2 it under seal. ECF Nos. 19 & 20. Hay argues that he is entitled to partial summary judgment in his 3 favor as to the issue of Defendants’ liability for the alleged unconstitutional use of a PBT without 4 a warrant or consent. ECF No. 20. However, Hay’s theory of liability fails as a matter of law 5 because, as the Court explains in this Order, the PBT administered by the Deputy was permitted 6 under the Fourth Amendment as a search incident to arrest. On August 14, 2023, Defendants filed 7 a motion for summary judgment as to each of Hay’s eight causes of action. ECF No. 22.

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Hay v. Kruger, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hay-v-kruger-nvd-2024.