Hunt v. Manchester

CourtDistrict Court, D. Connecticut
DecidedOctober 7, 2024
Docket3:22-cv-00450
StatusUnknown

This text of Hunt v. Manchester (Hunt v. Manchester) 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
Hunt v. Manchester, (D. Conn. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DANIEL HUNT, : : Plaintiff, : : v. : Case No. 3:22-cv-450(RNC) : TOWN OF MANCHESTER, : JOHN DOE #1, : JOHN DOE #2 & : OFFICER JOHN DOE #3, : : Defendants. :

RULING AND ORDER

Daniel Hunt commenced this action in state court against the Town of Manchester, town employees John Doe 1 and John Doe 2, and town police officer John Doe 3, seeking damages under state and federal law for injuries he allegedly sustained in an altercation with John Does 1 and 2 at Manchester Town Hall.1 The action was removed on the basis of the federal claims. The defendants have moved to dismiss the complaint for insufficiency of service of process under Federal Rule of Civil Procedure 12(b)(5), lack of personal jurisdiction under Rule 12(b)(2), and

1 The complaint contains eight counts under the following headings: “Count One: Civil Battery (All Defendants)”; “Count Two: Malicious Prosecution (All Defendants)”; “Count Three: Negligence Under 42 U.S.C. § 1986 (All Defendants)”; “Count Four: Use Of Excessive Force In Violation of 42 U.S.C. § 1983 (As To All Defendants)”; “Count Five: False Imprisonment (As To All Defendants)”; “Count Six: Intentional Infliction of Emotional Distress (As To All Defendants)”; “Count Seven: Negligent Infliction of Emotional Distress (As To All Defendants)”; and “Count Eight: Municipal Liability Under the Doctrine Set Forth in Monell v. Department of Social Services, 436 U.S. 658 (1978)(Town of Manchester), per 42 U.S.C. § 1986.” failure to state a claim on which relief may be granted under Rule 12(b)(6). For reasons stated below, the motion is granted. I.

The complaint alleges the following facts, which are assumed to be true for purposes of this ruling. On September 2, 2020, plaintiff went to the Manchester Town Hall to pay his taxes. When he was about to enter the tax collector’s office, John Doe 1 grabbed his arm, pulled the arm out of its socket, and pinned the plaintiff to the floor for several minutes. John Doe 2 either aided the assault or stood by allowing it to happen. John Does 1 and 2 were not trained in the use of force, restraint, or de-escalation, nor granted arrest powers. John Does 1 and 2 then conspired to bring false criminal charges against the plaintiff, which were dismissed.2 II. A. Claims Against the Doe Defendants

Defendants move to dismiss the claims against the Doe defendants on the ground that they have not been served with a writ of summons identifying them by name. Plaintiff argues that the Doe defendants were properly served via service on the Town

2 In his memorandum in opposition to the motion to dismiss, plaintiff adds the following: “The assault occurred under color of law as a consequence of the Plaintiff attempting to pay his taxes without wearing a mask. The John Doe Defendants then summoned an officer, and in conjunction, they conspired to maliciously prosecute him, said malicious prosecution terminating in his favor on June 18, 2021.” ECF 26, at 1. Clerk in Manchester of a summons using pseudonyms because their identities were unknown. He relies on Conn. Gen. Stat. § 52- 57(b)(7), which provides that, in a civil action against an

employee of a town arising from the employee’s duties, service is accomplished by serving two copies of the summons and complaint on the clerk of the town, who retains one copy and forwards the second copy to the employee. Neither the Connecticut Supreme Court nor the Appellate Court appears to have considered whether state law authorizes service of process on an unidentified town employee in the manner attempted here, that is, by serving the town clerk with a summons containing a pseudonym. However, in a case presenting this issue, Judge Bellis held that such service is not authorized. See Younger v. City of East Haven, No. CV0850205005, 2008 WL 4016615, at *2 - *4 (Conn. Super. Ct. Aug. 4, 2008)(claim against police officer sued

as John Doe dismissed because purported service on city clerk as agent for unidentified officer was insufficient). Judge Blue has similarly concluded that state law does not permit use of a pseudonym to serve a defendant whose identity is unknown. See also Brock v. A-1 Auto Service, Inc., 45 Conn. Sup. 525, 528-29 (Conn. Super. Ct. 1998). No authority to the contrary has been cited or found. In his opposition memorandum, plaintiff states: “The policy of the forum us (sic) clear: ‘The privilege of using fictitious names in actions should be granted only in the rare case where the nature of the issue litigated and the interest of the parties demand it and no harm can be done to the public interest.’ Buxton

v. Ullman, 147 Conn. 48, 60, 156 A.2d 508 (1959).” In Buxton, the plaintiffs requested permission to proceed anonymously, which is a far different matter than permitting a plaintiff to sue an unidentified defendant. As Judge Blue explained in Brock, “There is no particular problem in bringing an anonymous plaintiff before the court so long as a pseudonym is used to describe the real person appearing in court. An anonymous defendant, in contrast, presents formidable problems in this endeavor. If the defendant is not described with particularity in the process, that defendant simply cannot be brought before the court.” 45 Conn. Super. at 529. In his opposition memorandum, plaintiff also points to Conn.

Gen. Stat. § 47a-23(b), entitled “Notice to quit possession or occupancy of premises,” which permits an owner of property to serve a notice to quit using a pseudonym when the owner does not know the occupant’s name. However, neither this statute nor any other authorizes use of pseudonyms to serve process in other contexts. Based on the parties’ submissions and independent research, I think it is more likely than not that the Connecticut Supreme Court would agree with the reasoning in Younger and Brock. Accordingly, the claims against the three Doe defendants are dismissed for insufficient service of process under Rule 12(b)(5), and for lack of personal jurisdiction, for which proper service of process is a prerequisite, under Rule 12(b)(2). B. Claims Against the Town

Defendants also move to dismiss the claims against the Town under Rule 12(b)(6) for failure to state a claim on which relief may be granted. To withstand a motion to dismiss under Rule 12(b)(6), a complaint must present a claim that is “plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The plausibility standard requires a plaintiff to provide factual allegations permitting a reasonable inference that the defendant is liable for the alleged wrong. This requirement “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. Courts must dismiss claims that rely upon “[t]hreadbare recitals of the elements of a cause of action,

supported by mere conclusory statements.” Id. It is unclear which counts of the complaint are intended to plead a claim against the Town.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Buxton v. Ullman
156 A.2d 508 (Supreme Court of Connecticut, 1959)
Brock v. A-1 Auto Service, Inc.
728 A.2d 1167 (Connecticut Superior Court, 1998)

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Bluebook (online)
Hunt v. Manchester, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunt-v-manchester-ctd-2024.