Jean-Baptiste v. Froehlich

CourtDistrict Court, D. Connecticut
DecidedNovember 23, 2021
Docket3:21-cv-01482
StatusUnknown

This text of Jean-Baptiste v. Froehlich (Jean-Baptiste v. Froehlich) 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
Jean-Baptiste v. Froehlich, (D. Conn. 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

------------------------------x : OLES JEAN-BAPTISTE : Civ. No. 3:21CV01482(SALM) : v. : : OFFICER RYAN FROEHLICH, : et al. : November 23, 2021 : ------------------------------x

INITIAL REVIEW ORDER

Self-represented plaintiff Oles Jean-Baptiste (“plaintiff”), a pretrial detainee1 in the custody of the Connecticut Department of Correction (“DOC”), brings this action pursuant to 42 U.S.C. §1983 against a variety of defendants apparently associated with the Norwich Police Department. [Doc. #1]. Plaintiff has been granted leave to proceed in this matter in forma pauperis. See Doc. #2, Doc. #8. I. Standard of Review Pursuant to 28 U.S.C. §1915A, this Court is required to review any civil complaint filed by a prisoner, and must dismiss

1 The Court may “take judicial notice of relevant matters of public record[.]” Sanchez v. RN Debbie, No. 3:18CV01505(JCH), 2018 WL 5314916, at *2 n. 4 (D. Conn. Oct. 26, 2018) (citing Giraldo v. Kessler, 694 F.3d 161, 164 (2d Cir. 2012)). The Court takes judicial notice of the Connecticut DOC website, which reflects that plaintiff was admitted to custody on March 3, 2020, and has not been sentenced. See http://www.ctinmateinfo.state.ct.us/detailsupv.asp?id_inmt_num=2 49440 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. Although detailed allegations are not required, a complaint must include sufficient facts to afford the defendant fair notice of the claims and the grounds upon which they are based and to demonstrate a right to relief. See Bell Atlantic v. Twombly, 550 U.S. 544, 555-56 (2007). Conclusory allegations are not sufficient. See 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.” Bell Atlantic, 550 U.S. at 570. It is well-established that “[p]ro se complaints ‘must be construed liberally and interpreted to raise the strongest arguments that they suggest.’” Sykes v. Bank of Am., 723 F.3d 399, 403 (2d Cir. 2013) (quoting Triestman v. Fed. Bureau of

Prisons, 470 F.3d 471, 474 (2d Cir. 2006)). However, even self- represented parties must comply with Rule 8 and the other rules of pleading applicable in all federal cases. See Harnage v. Lightner, 916 F.3d 138, 141 (2d Cir. 2019). II. Allegations of the Complaint

The Court accepts the following allegations as true, solely for purposes of this initial review. On March 2, 2020, plaintiff was a passenger on a friend’s scooter, going home from a friend’s house. See Doc. #1 at 8. He “saw a police cruiser marked Norwich P.D. driving on the opposite side of the [road] with its emergency lights on.” Id. Plaintiff told his friend, who was apparently driving the

scooter, “to pull over on the scooter[.]” Id. Plaintiff then asserts: This is when the officer named Ryan Froehlich came out of his Norwich P.D. cruiser, and walked to me, then started viciously, intentionally assault and battery up on me for no reason by punching me on my face repeatedly and knocking me down to the ground.

After knocking me to the ground officer Ryan Froehlich started to tased me while I was still knocked to the ground. Officer Ryan Froehlich tased me on the left side of my head right on my temple.

Doc. #1 at 8 (sic). Plaintiff then lost consciousness. Froehlich checked his pulse and “tased [him] for a second time directly on [his] left side of [his] chest, right on [his] heart.” Id. Plaintiff contends: “Before the second tasing I was still unconscious.” Id. Plaintiff could then hear other officers and an ambulance arrive on scene. See id. at 8-9. He felt officers drag him across the road, and place him in the back of the cruiser. See id. at 9. He could tell he was “hidden in the back” of the cruiser, and alleges that his foot was “shut into the door of the cruiser.” Id. Plaintiff was then taken to the hospital, and was kept there overnight. See id. Once he was placed in DOC custody, he was sent to “UConn Hospital” for injuries to his head, eye, and heart, which he received from Norwich Police Officers. Id. III. Discussion

Plaintiff’s core allegations appear to be the following: Officer Ryan Froehlich used excessive force against me for no reason.

I was brutally beaten, assaulted, almost to death and other officers help hide me also intentionally almost killing me.

Doc. #1 at 9 (sic). The Court construes the Complaint, very generously, as asserting (A) a Fourth Amendment excessive force claim against Froehlich and (B) a failure to intervene claim against the remaining defendants. The Court construes the Complaint as bringing claims against all defendants in their individual capacities, for money damages; there is no demand for injunctive relief. While plaintiff names the City of Norwich and the Norwich Police Department as defendants, the Complaint makes no claims against them. A. Excessive Force – Defendant Froehlich Claims of excessive force in connection with a plaintiff’s arrest are considered under the Fourth Amendment rather the Eighth Amendment. See Graham v. Connor, 490 U.S. 386, 395 (1989) (“[A]ll claims that law enforcement officers have used excessive force ... in the course of an arrest, investigatory stop, or other “seizure” of a free citizen should be analyzed under the Fourth Amendment[.]”). The Fourth Amendment protects “[t]he right of the people to

be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures[.]” U.S. Const. amend. IV. The Fourth Amendment’s protection against unreasonable seizures prohibits the use of excessive force by police officers during the course of an arrest. See Hemphill v. Schott, 141 F.3d 412, 416-17 (2d Cir. 1998). To state a cognizable Fourth Amendment excessive force claim, a plaintiff must show that the force used by the defendants was “objectively unreasonable.” Graham, 490 U.S. at 397. “The ‘reasonableness’ of a particular use of force must be judged from the perspective of a reasonable police officer on the scene,” id. at 396, and it “requires consideration of the

severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether the suspect is actively resisting arrest or attempting to evade arrest by flight.” Hemphill, 141 F.3d at 417. The Complaint does not describe the use of force by any officer other than Froehlich. Plaintiff alleges that he was simply on the same road as defendant Froehlich, when Froehlich, who was on duty as a Norwich police officer at the time, physically attacked him without provocation or cause. See Doc. #1 at 8-9. Plaintiff alleges further that he required medical attention at a hospital as a result of this conduct. See id. at 9. At this stage of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Sykes v. Bank of America
723 F.3d 399 (Second Circuit, 2013)
Petaway v. City of New Haven Police Department
541 F. Supp. 2d 504 (D. Connecticut, 2008)
Roque v. Armstrong
392 F. Supp. 2d 382 (D. Connecticut, 2005)
Nicholson v. Lenczewski
356 F. Supp. 2d 157 (D. Connecticut, 2005)
Outlaw v. City of Hartford
884 F.3d 351 (Second Circuit, 2018)
Komondy v. Gioco
253 F. Supp. 3d 430 (D. Connecticut, 2017)
Giraldo v. Kessler
694 F.3d 161 (Second Circuit, 2012)
Harnage v. Lightner
916 F.3d 138 (Second Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Jean-Baptiste v. Froehlich, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jean-baptiste-v-froehlich-ctd-2021.