Holder v. Ericson

CourtDistrict Court, D. Connecticut
DecidedNovember 8, 2021
Docket3:21-cv-01305
StatusUnknown

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

Bluebook
Holder v. Ericson, (D. Conn. 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: KOIL DEMETROUS HOLDER, : Plaintiff, : CASE NO. 3:21-cv-1305 (MPS) : v. : : TAIS C. ERICSON, et al., : Defendants. : NOVEMBER 8, 2021 :

_____________________________________________________________________________

ORDER Plaintiff Koil Demetrous Holder, incarcerated at Corrigan-Radgowski Correctional Center in Uncasville, Connecticut, filed this case under 42 U.S.C. § 1983. The plaintiff names three defendants: Executive Director of Superior Court Operations Tais C. Ericson, State’s Attorney Jennifer Marze Barry, and Court Reporter Leslie F. Fialkievicz. The plaintiff seeks damages for several claims relating to his criminal case. The Court must review prisoner civil complaints and dismiss any portion of the complaint that is frivolous or malicious, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A. This requirement applies to all prisoner filings regardless whether the prisoner pays the filing fee. Nicholson v. Lenczewski, 356 F. Supp. 2d 157, 159 (D. Conn. 2005) (citing Carr v. Dvorin, 171 F.3d 115 (2d Cir. 1999) (per curiam)). Here, the plaintiff is proceeding in forma pauperis. Although detailed allegations are not required, the complaint must include sufficient facts to afford the defendants fair notice of the claims and the grounds upon which they are based and to demonstrate a plausible right to relief. Bell Atlantic v. Twombly, 550 U.S. 544, 555-56 (2007). Conclusory allegations are not sufficient. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.”

Twombly, 550 U.S. at 570. “A claim has facial plausibility when a plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (internal quotation marks and citation omitted). “Although courts must interpret a pro se complaint liberally, the complaint will be dismissed unless it includes sufficient factual allegations to meet the standard of facial plausibility.” See Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009) (citations omitted). I. Allegations In his Amended Complaint, the plaintiff generally alleges that his speedy trial motion was not heard for six months. ECF No. 14 ¶ 1. He also alleges that he was provided an “illegal attorney” and that his name was forged on an agreement with the state. Id. ¶ 2.

The plaintiff submitted paperwork to obtain a transcript from the court reporter but never received it. Id. ¶ 3. The plaintiff alleges that there never was an “established contact” with the alleged victim of his crime and contends that he was held because the state had no case but was trying to maintain its conviction rate. Id. ¶ 4. When the plaintiff wrote to defendant Ericson asking him to investigate this claim, defendant Ericson said he could not investigate the allegations. Id. ¶¶ 5-6. The plaintiff filed paperwork to obtain copies of the arrest warrant and police report, but 2 he alleges that defendant Barry refused to give him the copies. Id. ¶ 7. During a video conference regarding his criminal case, the court reporter, defendant Fialkievicz, laughed at the plaintiff because he continued to speak after she had “muted” him. She also stated that she would not provide him transcripts. Id. ¶¶ 8-10.

II. Analysis The plaintiff identifies no claims in his Amended Complaint. In the original Complaint, however, he states that defendants Ericson and Barry violated his Fourth, Fifth, Eighth, and Fourteenth Amendment rights to due process. See ECF No. 1 at 1. The court assumes the plaintiff intends to assert the same violations in the Amended Complaint. A. Fourth, Fifth, and Eighth Amendment Claims Records available on the Department of Correction website show that the plaintiff is unsentenced and being held on a charge of criminal violation of a protective order. See ctinmateinfr.state.ct.us/detailsupv.asp?id_inmt_num=162238. The Fourth Amendment generally applies to the period prior to arraignment when the inmate is in police custody. See Powell v.

Gardner, 891 F.2d 1039, 1044 (2d Cir. 1989) (Fourth Amendment applies through time of arraignment or formal charge). The Eighth Amendment affords protection for sentenced inmates. See Whitley v. Albers, 475 U.S. 312, 327 (1986) (noting that Eighth Amendment specifically concerns “the unnecessary and wanton infliction of pain in penal institutions” and, therefore, is “the primary source of substantive protection to convicted prisoners”). As the plaintiff has been arraigned but not yet convicted and sentenced, his claims are not cognizable under the Fourth or Eighth Amendments. The Due Process Clause of the Fifth Amendment applies to the federal government while 3 the Due Process Clause of the Fourteenth Amendment applies to the states. See Welch v. United States, 578 U.S. 120, 136 S. Ct. 1257, 1261-62 (2016). As no defendant is a federal official, the Fifth Amendment affords no protection to the plaintiff. All claims under the Fourth, Fifth, and Eighth Amendments are dismissed.

B. Defendant Ericson The plaintiff describes defendant Ericson as the Executive Director of Superior Court Operations, a supervisory official. He alleges that defendant Ericson refused his request for an investigation into the facts underlying his arrest and criminal charge. The Second Circuit has recently clarified the standard to be applied to a claim of supervisory liability. See Tangreti v. Bachmann, 983 F.3d 609 (2d Cir. 2020). Prior to the Supreme Court’s decision in Ashcroft v. Iqbal, 556 U.S. 662 (2009), the Second Circuit had identified five categories of conduct that would establish liability of supervisors for the conduct of a subordinate in a section 1983 action, one of which was failure to address unconstitutional acts when informed such acts were occurring. Id. at 616.

In Iqbal, the Supreme Court rejected a theory of supervisory liability that permitted a supervisor to be “held liable based on a lesser showing of culpability than the constitutional violation requires.” Id. at 617 (quoting Iqbal, 556 U.S. at 677) (internal quotation marks omitted). In Tangreti, the Second Circuit adopted this view and held that, “after Iqbal, there is no special rule for supervisory liability. Instead, a plaintiff must plead and prove “that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.’” Id. at 618 (quoting Iqbal, 556 U.S. at 676). Thus, the plaintiff must plead and prove that defendant Ericson was personally involved in the alleged constitutional violation. 4 The plaintiff alleges no facts suggesting that defendant Ericson was personally involved in his arrest or the decision to hold and prosecute him.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Powell v. Gardner
891 F.2d 1039 (Second Circuit, 1989)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Beverly v. Walker
899 F. Supp. 900 (N.D. New York, 1995)
Nicholson v. Lenczewski
356 F. Supp. 2d 157 (D. Connecticut, 2005)
Welch v. United States
578 U.S. 120 (Supreme Court, 2016)
Tangreti v. Bachmann
983 F.3d 609 (Second Circuit, 2020)
State v. Kinchen
707 A.2d 1255 (Supreme Court of Connecticut, 1998)

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Bluebook (online)
Holder v. Ericson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holder-v-ericson-ctd-2021.