Hickey v. Oklahoma County Detention Center

CourtDistrict Court, W.D. Oklahoma
DecidedMarch 29, 2022
Docket5:20-cv-01291
StatusUnknown

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

Bluebook
Hickey v. Oklahoma County Detention Center, (W.D. Okla. 2022).

Opinion

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

DEDRICK LEMONT HICKEY, ) ) Plaintiff, ) ) v. ) Case No. CIV-20-1291-R ) OKLAHOMA COUNTY ) DETENTION CENTER, et. al., ) ) Defendants. )

ORDER

Before the Court is Plaintiff Dedrick Lemont Hickey’s action pursuant to 42 U.S.C. § 1983. Doc. No. 1. Mr. Hickey, appearing before the Court pro se and in forma pauperis (IFP), has filed a Motion for Summary Judgment [Doc. Nos. 43, 45, 46].1 United States Magistrate Judge Gary M. Purcell entered a Supplemental Report and Recommendation in which he reasons the Court should deny Plaintiff’s motion and dismiss his complaint pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii). Doc. No. 59. Mr. Hickey has timely filed his objection, and the matter is ripe for adjudication. On de novo review, for the reasons set forth below, the Court ADOPTS the Supplemental Report and Recommendation, DENIES Plaintiff’s motion for summary judgment, and DISMISSES his action. Plaintiff’s claims focus on the allegedly wrongful confiscation of his property while he was incarcerated in the Oklahoma County Detention Center (OCDC). Id. at 2. On November 8, 2020, jail staff decided to move Mr. Hickey from the general population to

1 These documents are all essentially identical motions for summary judgment. Therefore, the Court solely references Plaintiff’s November 29, 2021, filing, Doc. No. 43, hereafter. the segregated housing unit (SHU). During the cell transfer, OCDC Detention Officer Christopher Rosales threw away two bags containing much of Plaintiff’s non-contraband property. Doc. No. 22 at 4. Mr. Hickey subsequently filed the instant § 1983 action.

Judge Purcell recommends the Court deny Plaintiff’s motion for summary judgement and dismiss his case pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii). Doc. No. 59 at 1. He reasons Mr. Hickey’s arguments are best construed as a First Amendment interference with access to the courts claim, an Eighth Amendment cruel and unusual punishment claim, and a Fourteenth Amendment due process claim. Id. at 6–9. Judge

Purcell recommends the Court find that Plaintiff has failed to properly plead a claim under any of these theories. Id. He alternatively recommends the Court dismiss Plaintiff’s claims because the current Defendants are not the proper parties, and Mr. Hickey has failed to join the proper defendant despite adequate time to do so. Id. at 12–16. Plaintiff objects on three grounds. First, he argues that the Oklahoma County

Criminal Justice Authority (Jail Trust) is a proper party. Doc. No. 64 at 1–2. Second, he disputes that jail has compensated him for his lost property, and he also contends Detention Officer Rosales acted intentionally when he discarded Plaintiff’s personal items. Id. at 3– 4. Finally, Mr. Hickey argues that he did not have the ability to join the proper party because he could not find out which jail employees had disposed of his personal property.

Id. at 4. The Court addresses each of these objections in turn. Judge Purcell did not address Plaintiff’s claims against the Jail Trust. Therefore, the Court will utilize its screening function for IFP cases found in § 1915(e)(2)(ii). “Dismissal of a pro se complaint for failure to state a claim is proper only where it is obvious that the plaintiff cannot prevail on the facts he has alleged[.]” Curley v. Perry, 246 F.3d 1278, 1281 (10th Cir.2001) (internal quotation omitted). “In determining whether a dismissal is proper, [the Court] must accept the allegations of the complaint as true and construe those

allegations, and any reasonable inferences that might be drawn from them, in the light most favorable to the plaintiff.” Gaines v. Stenseng, 292 F.3d 1222, 1224 (10th Cir. 2002). The Court applies the same standard of review for dismissals under § 1915(e)(2)(B)(ii) that it employs for Fed. R. Civ. P. 12(b)(6) motions to dismiss for failure to state a claim. See Mitchell v. Farcass, 112 F.3d 1483, 1490 (11th Cir. 1997)

(holding the standard of review for Rule 12(b)(6) and § 1915(e)(2)(B)(ii) dismissals are the same). In the Rule 12(b)(6) context, the Court looks for plausibility in the complaint. Alvarado v. KOB–TV, L.L.C., 493 F.3d 1210, 1215 (10th Cir. 2007). Specifically, the undersigned “look[s] to the specific allegations in the complaint to determine whether they plausibly support a legal claim for relief.” Id. at 1215 n. 2. “Factual allegations [in a

complaint] must be enough to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 545 (2007). “In addition, [the Court] must construe a pro se . . . complaint liberally.” Gaines, 292 F.3d at 1224. This liberal treatment is not without limits, and “[the Tenth Circuit] has repeatedly insisted that pro se parties follow the same rules of procedure that govern other litigants.” Garrett v. Selby, Connor, Maddux & Janer,

425 F.3d 836, 840 (10th Cir. 2005) (internal quotation marks omitted). Under Oklahoma law, a public trust such as the Jail Trust is a distinct legal entity, and its activities and obligations are determined by the written instrument under which it was created. See Okla. Stat. tit. 60, § 176 et seq. Plaintiff is correct that the Jail Trust is the ultimate operator of the OCDC. See Trust Indenture Creating the Criminal Justice Authority.2 However, in his complaint, Plaintiff does not provide any factual allegations that demonstrate the Jail Trust was responsible for the alleged violation of his constitutional

rights, and therefore the Court must dismiss his action pursuant to § 1915(e)(2)(B)(ii). Section 1983 does not authorize respondeat superior liability. See Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 691 (1978). Consequently, Plaintiff must allege a factual basis for the Jail Trust’s liability to state a claim pursuant to § 1983. Id. To do so, Mr. Hickey must plausibly plead that “the unconstitutional actions of an employee were representative

of an official policy or custom of the municipal institution, or were carried out by an official with final policy making authority with respect to the challenged action.” Ledbetter v. City of Topeka, Kansas, 318 F.3d 1183, 1189 (10th Cir. 2003) (quoting Camfield v. City of Oklahoma City, 248 F.3d 1214, 1229 (10th Cir. 2001)). There are five ways to establish an official policy or custom sufficient to impose

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Related

Mitchell v. Farcass
112 F.3d 1483 (Eleventh Circuit, 1997)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Curley v. Perry
246 F.3d 1278 (Tenth Circuit, 2001)
Camfield v. City of Oklahoma City
248 F.3d 1214 (Tenth Circuit, 2001)
Ledbetter v. City of Topeka, KS
318 F.3d 1183 (Tenth Circuit, 2003)
Garrett v. Selby Connor Maddux & Janer
425 F.3d 836 (Tenth Circuit, 2005)
Alvarado v. KOB-TV, L.L.C.
493 F.3d 1210 (Tenth Circuit, 2007)
McKinney v. Revell
364 F. App'x 430 (Tenth Circuit, 2010)
Gaines v. Stenseng
292 F.3d 1222 (Tenth Circuit, 2002)
Trujillo v. Williams
465 F.3d 1210 (Tenth Circuit, 2006)

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Bluebook (online)
Hickey v. Oklahoma County Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hickey-v-oklahoma-county-detention-center-okwd-2022.