Jefferson v. State of Texas

CourtDistrict Court, S.D. Texas
DecidedOctober 28, 2019
Docket4:19-cv-03497
StatusUnknown

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

Bluebook
Jefferson v. State of Texas, (S.D. Tex. 2019).

Opinion

Southern District of Texas ENTERED IN THE UNITED STATES DISTRICT COURT so □□□□□□ olen FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION KAREEM ROSCHARD JEFFERSON, § Plaintiff, Vv. : CIVIL ACTION No. H-19-3497 STATE OF TEXAS, Defendant.

MEMORANDUM OPINION AND ORDER Harris County pretrial detamee Kareem Roschard Jefferson, a/k/a Kareem Roshard Jefferson, a/k/a Richard Jefferson, a/k/a Benjamin Brown, filed this pro se section 1983 lawsuit complaining of violations of his constitutional rights. He proceeds in forma pauperis and names as defendants the State of Texas and Harris County. Having considered the complaint, matters of public record, and the applicable law, the Court DISMISSES this lawsuit for the reasons that follow. Background and Claims Plaintiff is in pretrial custody of the Harris County Sheriff’s Office awaiting trial on felony charges for the assault of Alexander Ramos, a public servant. He claims that he was not brought before a magistrate or given his Miranda warnings. He further claims he was unaware he had been formally charged or that bail had been set, and that he was appointed counsel without his consent. Plaintiff further contends that Harris County is guilty of negligence in its training and supervision, and that it encourages a custom of

physical, verbal, and emotional abuse. He does not allege that he incurred any injury as a result of the negligence or custom. Plaintiff seeks monetary damages and “wide spread changes in policy.” Analysis When a prisoner proceeds in forma pauperis in a civil action, the Court shall evaluate the complaint and dismiss it without service of process if the Court finds that the complaint is frivolous, malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915A, 1915(e)(2)(B). A claim is frivolous if it has no arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319 (1989). A claim has no arguable basis in law if it is based on an indisputably meritless legal theory, “such as if the complaint alleges the violation of a legal interest which clearly does not exist.” Davis v. Scott, 157 F.3d 1003, 1005 (Sth Cir. 1998). A claim has no arguable basis in fact if “after providing the plaintiff the opportunity to present additional facts when necessary, the facts alleged are clearly baseless.” Talib v. Gilley, 138 F.3d 211, 213 (Sth Cir. 1998). Claims Barred by Sovereign Immunity Plaintiff's claims for monetary damages against the State of Texas are barred by sovereign immunity and are DISMISSED WITH PREJUDICE. See Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89, 100-01 (1984). Moreover, because the State of Texas is not liable for any customs promulgated or practiced by Harris County as to the

Harris County Jail, plaintiff alleges no viable claim under section 1983 against the State of Texas. Claims Barred by Heck Plaintiff claims that he was not “Mirandized.” The Court construes this allegation as raising a claim for violation of Miranda vy. Arizona, 384 U.S. 436, 475 (1966). Any failure of law enforcement authorities to read plaintiff his Miranda warnings does not raise a viable section 1983 claim at this time. Because plaintiff seeks monetary damages for alleged wrongful pretrial detention premised on a Miranda violation, his claim is barred by Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). See, e.g., Bickman v. Blair, 2000 WL 1056096, at *1 (Sth Cir. 2000). Plaintiffs claim is DISMISSED WITH PREJUDICE to being asserted again until the Heck conditions are met. Johnson v. McElveen, 101 F.3d 423, 424 (Sth Cir. 1996). Procedural Due Process Plaintiff alleges that he was not brought before a magistrate, was unaware he had been formally charged or that bail had been set, and was appointed counsel without his consent. These allegations of procedural due process violations are refuted by state court records or do not raise an issue of federal constitutional dimension. A review of public online court records in State v. Jefferson, Cause No. 1626298 pending in the 178th District Court of Harris County, Texas, shows that a criminal complaint was filed against plaintiff on March 29, 2019. Plaintiff was in jail custody at the time on other criminal charges. The complaint alleged that plaintiff struck the

complainant, Alexander Ramos, while the complainant was securing prisoners at the jail. Plaintiff was not personally brought before a magistrate for a probable cause hearing as he was already in custody on other criminal charges. He was appointed counsel on April 1, 2019, and counsel reset plaintiffs arraignment hearing dates. The record shows that plaintiff was later indicted and was personally served a copy of his indictment while in jail on July 1, 2019. The record further shows that plaintiff was aware bail had been set, as he filed a pro se motion to reduce the bond amount on August 22, 2019. To the extent plaintiff complains that he was appointed counsel without his consent, he has no constitutional right to be appointed counsel of his choice. See, e.g., United States v. Conlan, 786 F.3d 380, 391 (Sth Cir. 2015). Plaintiff’s motion to waive counsel and proceed pro se in his criminal prosecution remains pending before the state court. Plaintiff’s factual allegations fail to state a viable claim for which relief can be granted under section 1983, and these claims are DISMISSED WITH PREJUDICE.

Custom or Policy Claim Plaintiff further contends that Harris County encourages a custom of physical, verbal, and emotional abuse. He seeks monetary damages as well as unspecified “wide spread” policy changes. The law is clear that allegations regarding threats or verbal abuse, even if true, do not state claims of constitutional significance. See Orange v. Ellis, 348 F. App’x 69, 72 (5th Cir. 2009); McFadden v. Lucas, 713 F.2d 143, 146 (Sth Cir. 1983). Consequently,

plaintiff's allegations as to verbal and emotional abuse do not rise to the level of a constitutional deprivation, and no viable claim is raised under section 1983. A municipality such as Harris County may be liable under section 1983 where “(1) an official policy (2) promulgated by the municipal policymaker (3) was the moving force behind the violation of a constitutional right.” Hicks-Fields vy. Harris County, Texas, 860 F.3d 803, 808 (Sth Cir. 2017); see also Monell v. Dep’t of Social Services, 436 U.S. 658, 694 (1978). “Official [local-government] policy includes the decisions of a government’s lawmakers, the acts of its policymaking officials, and practices so persistent and widespread as to practically have the force of law.” Connick v. Thompson, 563 U.S. 51, 60 (2011); see also Peterson v.

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Related

Talib v. Gilley
138 F.3d 211 (Fifth Circuit, 1998)
Randell Orange v. Emanuel Ellis
348 F. App'x 69 (Fifth Circuit, 2009)
Peterson v. City of Fort Worth, Tex.
588 F.3d 838 (Fifth Circuit, 2009)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Pennhurst State School and Hospital v. Halderman
465 U.S. 89 (Supreme Court, 1984)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Clarence Enochs v. Lampasas County
641 F.3d 155 (Fifth Circuit, 2011)
Alan Kimbrough McFadden v. Eddie Lucas
713 F.2d 143 (Fifth Circuit, 1983)
United States v. Joshua Conlan
786 F.3d 380 (Fifth Circuit, 2015)
Marie Hicks-Fields v. Christopher Pool
860 F.3d 803 (Fifth Circuit, 2017)
Connick v. Thompson
179 L. Ed. 2d 417 (Supreme Court, 2011)

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Bluebook (online)
Jefferson v. State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-v-state-of-texas-txsd-2019.