Houy v. Logsdon

CourtDistrict Court, W.D. Kentucky
DecidedJuly 23, 2021
Docket4:20-cv-00184
StatusUnknown

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

Bluebook
Houy v. Logsdon, (W.D. Ky. 2021).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY OWENSBORO DIVISION Ted Houy Plaintiff v. No.4:20-cv-184-BJB-HBB Jeremy S. Logsdon Defendant Opinion and Order Plaintiff Ted Houy allegedly entered into an oral agreement that allowed him to store personal property in a building owned by Charles Edwards. Complaint (DN 1) ¶ 9. Sometime in 2019, according to the complaint, Houy and Edwards had a falling out: Edwards wants Houy’s property out of Edwards’ building, while Houy accuses Edwards of trying to take the property for himself. ¶¶ 10–14. But this case does not concern that property directly; it’s a dispute about the dispute. Houy isn’t even suing Edwards. He’s suing Jeremy Logsdon, the Grayson County Attorney and the lawyer Edwards allegedly retained to represent him after his relationship with Houy soured. ¶ 11. Why Logsdon? Because a demand letter on his Grayson County Attorney letterhead said that Edwards would treat Houy’s property as his own unless Houy removed it within 30 days. ¶ 14; Logsdon Letter (DN 11-5) at 1 (“Mr. Edwards shall be within his rights to declare the equipment/property abandoned and will deal with the property as his own.”). This letter, Houy claims, “sought to deprive [Houy] of his personal property … without due process of law … in violation of the Fourteenth and Fifth Amendments.” ¶ 15. So Houy sued Logsdon in federal court alleging violation of his constitutional rights under color of state law in violation of 42 U.S.C. § 1983. ¶¶ 13–17. Houy also asserted various claims for official misconduct under Kentucky law. ¶¶ 18–23. Logsdon filed the motion to dismiss (DN 6) now pending before this Court. He argues that no one has actually deprived Houy of any property, and that the mere threat of losing property doesn’t support a due process claim. Motion to Dismiss (6-1) at 7–8. Even if Houy had alleged actual deprivation, Logsdon contends, the § 1983 claim should also fail because Houy never alleged that state-law procedures following any deprivation were inadequate to address any loss suffered by Houy—another essential element of a due process claim. Id. at 8–10 (citing Sutton v. Cleveland Bd. of Educ., 958 F.3d 1339, 1349 (6th Cir. 1992)). Houy filed a motion to amend his complaint and a response to Logsdon’s motion to dismiss, candidly acknowledging these deficiencies regarding his federal claim: “If Plaintiff’s Motion to Amend is denied, then it would appear that Plaintiff’s Complaint should be dismissed under the authorities cited by the Defendant.” Response to Motion to Dismiss (DN 12) at 1; see also Motion for Leave to Amend (DN 11). Logsdon opposes Houy’s request to amend on the ground that it still wouldn’t save Houy’s federal claim. See Response to Motion to Amend (DN 14)at 5–9. These papers pay scant attention to the state-law claims accompanying the due-process allegation. But they do explain that parallel eviction proceedings are underway in state court. See id. at 3, 6–7; Proposed First Amended Complaint (FAC) (DN 11-3) at ¶ 16.

After holding a hearing on these motions, the Court grants Logsdon’s motion to dismiss because Houy has not alleged any actual deprivation of his property. The Court also denies Houy’s motion for leave to amend because the proposed first amended complaint would not save his federal claim.

Standards of Review

Motion to dismiss. To survive a motion to dismiss, a claim must be “plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible 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) (citing Twombly, 550 U.S. at 556). In other words, the claim must contain “either direct or inferential allegations respecting all material elements necessary for recovery under a viable legal theory.” Phila. Indem. Ins. Co. v. Youth Alive, Inc., 732 F.3d 645, 649 (6th Cir. 2010) (internal quotation marks omitted). Courts must accept these factual allegations as true, but needn’t accept a plaintiff’s mere legal conclusions. Iqbal, 556 U.S. at 678.

Leave to amend. Courts “should freely give” leave to amend “when justice so requires.” Fed. R. Civ. P. 15(a)(2). “[I]mplicit in Rule 15(a) is that the district court must be able to determine whether ‘justice so requires,’ and in order to do this, the court must have before it the substance of the proposed amendment.” Beydoun v. Sessions, 871 F.3d 459, 469 (6th Cir. 2017) (alterations adopted) (quoting Roskam Baking Co., Inc. v. Lanham Machinery Co., Inc., 288 F.3d 895, 906 (6th Cir. 2002)). Though “commonly granted, a motion to amend should nevertheless ‘be denied if the amendment would be futile.’” Courie v. Alcoa Wheel & Forged Prods., 577 F.3d 625, 633 (6th Cir. 2009) (quoting Crawford v. Roane, 53 F.3d 750, 753 (6th Cir. 1995)). “A proposed amendment is futile if the amendment could not withstand a Rule 12(b)(6) motion to dismiss.” Beydoun, 871 F.3d at 469 (quoting Riverview Health Inst. LLC v. Med. Mut. of Ohio, 601 F.3d 505, 520 (6th Cir. 2010)).

Discussion

Because Houy acknowledges that his original complaint wouldn’t survive a motion to dismiss, see Response to Motion to Dismiss at 1, the Court focuses its analysis on whether the proposed amended complaint would save Houy’s clams from dismissal. See West v. Dep’t of Veterans Affs., No. 3:19-cv-911, 2021 WL 1294786, at *1 (W.D. Ky. April 7, 2021) (“[I]f some of the defects raised in the original motion remain in the new pleading, the court simply may consider the motion as being addressed to the amended pleading.”) (alterations adopted) (quoting Rountree v. Dyson, 892 F.3d 681, 683–84 (5th Cir. 2018)); see also Wright & Miller, 6 Fed. Prac. & Proc. Civ. § 1476 (3d ed.) (same). The proposed amended complaint, however, suffers from most of the same dispositive deficiencies.

Federal claims. “In a procedural-due-process claim, the deprivation of property by state action is not itself unconstitutional; what is unconstitutional is the deprivation of such an interest without due process of law.” Kaminski v. Coulter, 865 F.3d 339, 347 (6th Cir. 2017) (quotation marks omitted). “In order to determine whether a due-process violation has occurred, we must first ask whether the plaintif[f] w[as] deprived of a constitutionally protected property right.” Id. If so, courts “must then ask if the process provided was constitutionally adequate.” Id.

Houy hasn’t alleged that anyone has already actually deprived him of the property he says he stored in Edwards’ building. Houy’s allegations in the proposed amended complaint clearly fall short of alleging an actual deprivation of property:

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Houy v. Logsdon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houy-v-logsdon-kywd-2021.