Henry Joseph Jaquez v. Cherokee County, John Bennett, Haley Robison, Rachel Marie Dallis, Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones

CourtDistrict Court, E.D. Oklahoma
DecidedFebruary 23, 2026
Docket6:23-cv-00410
StatusUnknown

This text of Henry Joseph Jaquez v. Cherokee County, John Bennett, Haley Robison, Rachel Marie Dallis, Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones (Henry Joseph Jaquez v. Cherokee County, John Bennett, Haley Robison, Rachel Marie Dallis, Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones) is published on Counsel Stack Legal Research, covering District Court, E.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry Joseph Jaquez v. Cherokee County, John Bennett, Haley Robison, Rachel Marie Dallis, Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones, (E.D. Okla. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

HENRY JOSEPH JAQUEZ,

Plaintiff,

v. Case No. 23-CV-410-JFH-DES

CHEROKEE COUNTY, JOHN BENNETT, HALEY ROBISON, RACHEL MARIE DALLIS, JOHNNY DALLIS, CHRIS SHRUM, THOMAS SCROGGINS, DAYNA COHEN, SAWYER WYSE, RICHARD SOURJOHN, JEREMY HUFF, MEGAN FORD, TAMERA SUMMERS, SYLVIA HOLMES and ROBERT JONES,

Defendants.

OPINION AND ORDER This civil rights action, brought pursuant to 42 U.S.C. § 1983, is before the Court on Defendants John Bennett and Haley Robinson’s (collectively, “District Attorney Defendants”) Motion to Dismiss [Dkt. No. 38], Defendant Cherokee County’s Motion to Dismiss [Dkt. No. 41], Defendants Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones’ (collectively, “Cherokee County Jail Defendants”) Motion to Dismiss [Dkt. No. 42] and Defendant Rachel Dallis’ Motion to Dismiss [Dkt. No. 49]. In addition to the Motions to Dismiss [Dkt. Nos. 38, 41, 42 and 49], the Court has before it Plaintiff Henry Joseph Jaquez’s (“Plaintiff”) Complaint [Dkt. No. 1], Plaintiff’s Response to the District Attorney Defendants’ Motion to Dismiss [Dkt. No. 46], Plaintiff’s Response to the Cherokee County Jail Defendants’ Motion to Dismiss [Dkt. No. 47], the Cherokee County Jail Defendants’ Reply [Dkt. No. 50] and Plaintiff’s Response to Defendant Rachel Dallis’ Motion to Dismiss [Dkt. No. 51]. BACKGROUND At the time of filing his Complaint, Plaintiff was a pretrial detainee at Cherokee County Detention Center. Dkt. No. 1 at 3.1 Plaintiff initiates this suit against numerous defendants

alleging nine (9) separate constitutional violations. Some of Plaintiff’s claims challenge the conditions of his confinement while detained at Cherokee County Jail. Plaintiff alleges he was deprived outdoor recreation (Claim 1), prohibited from seeing a chaplain and threatened for reading his Bible out loud infringing on his right to exercise his religion (Claim 3) and he was prohibited from speaking violating the First Amendment (Claim 4). Plaintiff also alleges he has initiated many complaints, grievances and lawsuits which have resulted in retaliation (Claim 8) and that one time when he asked for a copy of his Prison Rape Elimination Act (“PREA”) complaint he was sprayed with O.C. chemical agents (Claim 2). For his final claim, he alleges he was deprived procedural due process while detained (Claim 9). Plaintiff’s other claims stem from one overarching situation. Plaintiff alleges he sent a

letter to the District Attorney’s office offering to provide information regarding two inmates ongoing cases in exchange for a lesser sentence in his case. Plaintiff alleges the District Attorney Defendants provided the letter to defense attorney Rachel Dallis, Rachel Dallis informed the inmates of Plaintiff’s letter, the inmates expressed an intention to “get” Plaintiff, the Cherokee County Jail Defendants were aware of the situation and helped orchestrate an opportunity for the inmates to assault Plaintiff and Plaintiff was in fact assaulted. This situation gives rise to Plaintiff’s claims for cruel and unusual punishment/failure to protect with retaliation (Claim 5), excessive

1 The Court’s citations refer to the CM/ECF header pagination. force (Claim 6) and deliberate indifference with reckless disregard for health and safety (Claim 7). Plaintiff names the following defendants: Cherokee County, John Bennett, Haley Robison, Rachel Dallis, Jonny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones.

Dkt. No. 1 at 2-9. Each Defendant responded to Plaintiff’s Complaint with a motion to dismiss. The Court analyzes Plaintiff’s claims and each motion in detail below. DISCUSSION I. Standard of Review Under Rule 12(b)(6) of the Federal Rules of Civil Procedure, a complaint should be dismissed for failure to state a claim upon which relief can be granted “only when it appears that the plaintiff can prove no set of facts in support that would entitle him to relief, accepting the well- pleaded allegations of the complaint as true and construing them in the light most favorable to the plaintiff.” Dubbs v. Head Start, Inc., 336 F.3d 1194, 1201 (10th Cir. 2003) (quoting Yoder v. Honeywell, Inc., 104 F.3d 1215, 1224 (10th Cir. 1997)). When determining whether to grant a

motion to dismiss, the district court is limited to assessing the legal sufficiency of the allegations contained within the four corners of the complaint. Jojola v. Chaves, 55 F.3d 488, 494 (10th Cir. 1995). “The court’s function on a Rule 12(b)(6) motion is not to weigh potential evidence that the parties might present at trial, but to assess whether the plaintiff’s complaint alone is legally sufficient to state a claim for which relief may be granted.” Id. (internal quotations and citations omitted). A request for dismissal pursuant to Rule 12(b)(6) requires the Court to determine whether the complaint contains “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). Although the Court is required to exercise a liberal interpretation of Plaintiff’s pleadings, Haines v. Kerner, 404 U.S. 520-21 (1972), the Court need not assume the role of advocate for Plaintiff,

and he must present more than conclusory allegations to survive a motion to dismiss for failure to state a claim, Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). “[C]onclusory allegations without supporting factual averments are insufficient to state a claim upon which relief can be based.” Id. (citing cases). “[A] pro se plaintiff requires no special legal training to recount the facts surrounding his alleged injury, and he must provide such facts if the court is to determine whether he makes out a claim on which relief can be granted.” Id. II. The District Attorney Defendants’ Motion to Dismiss [Dkt. No. 38] The Court first addresses the District Attorney Defendants’ Motion to Dismiss. Throughout his Complaint, Plaintiff alleges he “sent voluntary statements about this serious matter to, ‘John Bennett,’ and, ‘Haley Robison[.]’” Dkt. No. 1 at 11 (internal punctuation and quotations

in original), see also id. at 14, 17, 21, 26-27 and 35. Plaintiff appears to assert for all the alleged wrongs he suffered while a pre-trial detainee, he made the District Attorney Defendants aware of these instances “to no avail.” Id. at 11, see also id. at 14, 17 (District Attorney Defendants “always ignore my pleadings, complaints, and appeals, with disregard.”), 21 (“These pleadings, and, appeals, and, statements, are also to no avail, and, no relief.”), and 27 (“to absolutely no avail”). Plaintiff also alleges he sent a letter to the District Attorney Defendants containing information he gathered from fellow detainees regarding their cases, the District Attorney Defendants gave the letter to a defense attorney, Rachel Dallis, and Rachel Dallis informed the implicated detainees of Plaintiff’s letter leading to Plaintiff being assaulted. See id. at 22-26, 31-34.

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Henry Joseph Jaquez v. Cherokee County, John Bennett, Haley Robison, Rachel Marie Dallis, Johnny Dallis, Chris Shrum, Thomas Scroggins, Dayna Cohen, Sawyer Wyse, Richard Sourjohn, Jeremy Huff, Megan Ford, Tamera Summers, Sylvia Holmes and Robert Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-joseph-jaquez-v-cherokee-county-john-bennett-haley-robison-rachel-oked-2026.