Holder v. Town of Newton, et al.

2009 DNH 110
CourtDistrict Court, D. New Hampshire
DecidedJuly 23, 2009
DocketCV-08-197-JL
StatusPublished

This text of 2009 DNH 110 (Holder v. Town of Newton, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holder v. Town of Newton, et al., 2009 DNH 110 (D.N.H. 2009).

Opinion

Holder v. Town of Newton, et al. CV-08-197-JL 07/23/09 P UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Ralph Holder

v. Civil No. 08-CV-197-JL Opinion No. 2009 DNH 110 Town of Newton et a l .

O R D E R

This civil rights action involves the constitutional

dimensions of pretrial detention and bail, as well as the

pleading reguirements in § 1983 case against municipalities.

Ralph Holder has sued the towns of Newton and East Kingston,

their police chiefs, certain of their police officers, the

Rockingham County Department of Corrections, and its

superintendent, alleging a number of constitutional violations

and common-law torts arising out of his arrest, detention, and

prosecution on a simple assault charge that was ultimately

dismissed. Two of the defendants, the Rockingham County

Department of Corrections and its superintendent, Albert J.

Wright (the "county defendants") moved to dismiss Holder's

constitutional claims against them, arguing that they fail to

state a claim for relief. See Fed. R. Civ. P. 12 (b) (6) .1 In

1Because the county defendants submitted an answer to the complaint before moving to dismiss it, their motion is properly treated as a motion for judgment on the pleadings under Rule 1 2 (c). The distinction, however, is largely academic, as Rule particular, the county defendants argue that (1) their continued

detention of Holder, even after he had allegedly been determined

to be eligible for release on bail, was not unconstitutional and

(2) Holder has not pled any policy or practice of deliberate

indifference to medical needs sufficient to establish a

constitutional claim for the county defendants' allegedly

depriving him of access to his prescription medications.

This court has subject-matter jurisdiction under 28 U.S.C. §

1331 (federal guestion) and 1367 (supplemental jurisdiction) .

After oral argument, the motion to dismiss is granted in part and

denied in part.2 There is ample authority that the Constitution

12(b) (6) and Rule 12(c) impose identical standards. See, e.g.. Gray v. Evercore Restructuring L.L.C., 544 F.3d 320, 324 (1st Cir. 2008). Furthermore, while Holder has since filed an amended complaint as ordered by this court at the preliminary pretrial conference, the amendment, as contemplated by the order, simply specifies which of the defendants are named to each count without changing the substance of the allegations at all. So the court has treated the motion to dismiss as directed at the amended complaint. See Hall v. Brooks, 2009 DNH 015, 2 n.2, appeal docketed. No. 09-1594 (1st Cir. Apr. 24, 2009). Holder, moved to strike the motion to dismiss as an improperly supported motion for summary judgment. While that relief has been denied, the court has treated the motion to strike as an objection to the motion to dismiss.

2The county defendants also filed a "supplemental motion to dismiss," joining in a motion to dismiss filed by other defendants that was based on Holder's failure to make initial disclosures in a timely fashion. That motion, as filed by the other defendants, was denied by margin order of March 25, 2009. The county defendants' reguest for the same relief is now denied for the same reasons.

2 prohibits "overdetention" of the kind the court understands

Holder to allege. But Holder has not alleged adeguate facts to

support his other claim: that the county defendants were

deliberately indifferent to his medical needs as the result of

their policy or practice. So while his complaint states an

overdetention claim for which relief can be granted, the medical

care claim is dismissed.

I. Applicable legal standard

To state a claim for relief, a complaint must set forth

"[f]actual allegations [that are] enough to raise a right to

relief above the speculative level, on the assumption that all of

the allegations in the complaint are true (even if doubtful in

fact)." Bell At1. Corp. v. Twombly, 550 U.S. 544, 555 (2007)

(citations and footnote omitted). This showing "reguires more

than labels and conclusions, and a formulaic recitation of the

elements of a cause of action will not do." Id. By the same

token, the showing does not reguire "detailed factual

allegations," id., simply "enough factual matter (taken as true)

to suggest" the plaintiff's right to relief. Id. at 556.

3 II. Background

Following Holder's arrest by local police in May 2005, he

was detained in the Rockingham County House of Corrections.

Holder alleges that "after the Bail Commissioner was informed of

the charges and determined that [Holder] was eligible for and

entitled to release on personal recognizance," the county

defendants "intentionally denied him prompt release, holding him

for an additional nine hours on the pretext of a purported

policy" that "prohibit[ed] the release of protective custody

detainees without a ride." Holder alleges he was not in

protective custody but, even if he had been, "he could have

called a cab or otherwise obtained a ride." Holder also alleges

that he "told officers at intake that he was insulin dependant

and hypertensive," but that he was nevertheless deprived of his

prescription medications for his whole nine-hour detention.

III. Analysis

A. Claim for denial of release

As clarified by the recent amendment, see note 1, supra.

Holder's complaint asserts a claim against the county defendants

under 42 U.S.C. § 1983, alleging that they "deprived [him] of his

constitutionally and statutorily protected right to reasonable

and prompt bail . . . in violation of Part I, Articles 15 and 33

4 of the New Hampshire Constitution as well as the Fifth, Eighth,

and Fourteenth Amendments to the United States Constitution." In

moving to dismiss this claim, the county defendants argue that

the federal Constitution "contains no right to immediate release

after bail" but, even if it did, that right could not have been

violated by Holder's claimed nine-hour detention as a matter of

law.3 That is not correct.

"There is a substantial body of law in support of the

proposition that a plaintiff who alleges overdetention, sometimes

even for a very short period, states a claim for constitutional

violations." Barnes v. District of Columbia, 242 F.R.D. 113, 117

(D.D.C. 2007) (citing cases); see also, e.g.. Berry v. Baca, 379

F.3d 764, (9th Cir. 2004); Davis v. Hall, 375 F.3d 703, 714 (8th

Cir. 2004); Lewis v. O'Grady, 853 F.2d 1366, 1370 (7th Cir.

1988); Douthit v. Jones, 619 F.2d 527, 532 (5th Cir. 1980). In

this context, "overdetention" means simply that the plaintiff has

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