Jipson v. Workman

CourtDistrict Court, E.D. Kentucky
DecidedJune 21, 2024
Docket5:24-cv-00026
StatusUnknown

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

Bluebook
Jipson v. Workman, (E.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION AT LEXINGTON

HILLARY JIPSON and CASE NO. 5:24-CV-26-KKC ELIJAH REEVES, Plaintiffs, v. OPINION AND ORDER ROBERT WORKMAN, Individually and in his capacity as Montgomery County Sheriff Deputy, and MONTGOMERY COUNTY SHERIFF DEPARTMENT, Defendants.

*** *** *** This matter is before the Court on a motion to remand (DE 8) filed by plaintiffs Hillary Jipson and Elijah Reeves (collectively, “Plaintiffs”) and a motion to dismiss (DE 3) filed by defendants Robert Workman and the Montgomery County Sheriff’s Department (collectively, “Defendants”). For the following reasons, the Court will grant the motion to dismiss in part and grant the motion to remand. I. Background On January 10, 2023, Plaintiffs were involved in a car accident in Bourbon County when defendant Robert Workman (“Workman”) attempted a left turn in front of their vehicle. This turn resulted in contact and damage to Plaintiffs’ vehicle. Plaintiffs assert that Workman then exited his vehicle and shouted expletives at Reeves while attempting to forcibly open Plaintiffs’ passenger door. During this time, Workman did not produce a badge and was not wearing his police uniform but warned the pair that he was “a f****** cop[.]” (DE 1-1 at 5.) No markings on Workman’s vehicle indicated that he was a law enforcement officer. (Id.) Uniformed deputies from the Montgomery County Sheriff’s Department, Workman’s employer, quickly arrived from “no less than two counties” away and began conducting an official investigation. (Id. at 7.) They did not allow Plaintiffs to leave. (Id. at 8.) Almost a year later, Plaintiffs filed this action against Defendants in the Bourbon Circuit Court. Plaintiffs bring the following claims: (1) deprivation of constitutional rights under 42 U.S.C. § 1983; (2) harassment under KRS § 525.070; (3) negligence; and (4) false imprisonment. (Id. at 9-10.) Defendants removed this action to this Court soon after its filing on the basis of federal-question and supplemental jurisdiction. Then, they filed a motion to dismiss Plaintiffs’ claims and invoke immunity for the Montgomery County Sheriff’s Department and Workman in his official capacity. Plaintiffs responded to this motion and filed their own motion to remand. Now that briefing has been completed pursuant to the local rules, these motions are ripe for the Court’s review. II. Analysis A. Subject-Matter Jurisdiction From the outset, Plaintiffs incorrectly argue that the federal-officer removal statute, 28 U.S.C. § 1442, requires the remand of this action. This action, however, was not removed under that statute, nor is it mentioned anywhere in the Notice of Removal. (DE 1.) These facts make the bulk of Plaintiffs’ arguments for remand entirely inapplicable. The Court has subject-matter jurisdiction over this action. In removing this case, Defendants relied on 28 U.S.C. § 1331 and § 1367(a), the statutes for original jurisdiction and supplemental jurisdiction. Section 1331 states that “district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. Case law makes it clear that § 1983 claims arise under federal law and district courts have jurisdiction to hear them pursuant to 28 U.S.C. § 1331. Grable & Sons Metal Prods., Inc. v. Darue Engineering & Mfg., 545 U.S. 308, 312 (2005) (“This provision for federal-question jurisdiction is invoked by and large by plaintiffs pleading a cause of action created by federal law (e.g., claims under 42 U.S.C. § 1983).”). Indeed, Plaintiffs concede that federal courts can hear § 1983 claims in its own motion to remand. (DE 8 at 3.) Next, Defendants argue that supplemental jurisdiction, 28 U.S.C. § 1367(a), attaches to the Plaintiffs’ state law claims. Section 1367(a) states that: “[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy . . . .” 28 U.S.C. § 1367(a). Here, the § 1983 claims and state law claims stem from the same altercation between Plaintiffs and Workman. Neither Plaintiffs nor Defendants dispute that fact. As a result, it is clear that these claims form part of the “same case or controversy” for the purpose of supplemental jurisdiction and this Court has subject-matter jurisdiction to hear the pending claims. Accordingly, Defendants’ removal from state court was proper. Plaintiffs do, however, argue that remand is still appropriate if the Court decides to dismiss the § 1983 claims. To address this argument, the Court must turn to the Defendants’ pending motion to dismiss. B. Section 1983 Claims A motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) tests the sufficiency of the complaint. The Court must “construe the complaint in the light most favorable to the plaintiff, accept its allegations as true, and draw all inferences in favor of the plaintiff.” DirecTV, Inc. v. Treesh, 487 F.3d 471, 476 (6th Cir. 2007). However, it “need not accept as true legal conclusions or unwarranted factual inferences.” Id. (quoting Gregory v. Shelby County, 220 F.3d 433, 446 (6th Cir. 2000)). The Supreme Court has explained that “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)) (quotation marks omitted). While a complaint need not have detailed factual allegations, a formulaic recitation of the elements will not suffice. Twombly, 550 U.S. at 555. Plaintiffs bring § 1983 claims against Defendants in an attempt to remedy an alleged violation of Plaintiffs’ constitutional rights. Section 1983 provides a federal cause of action to a person whose rights “secured by the Constitution” are violated by an official acting “under color of [State law].” 42 U.S.C. § 1983. In this way, § 1983 “creates a species of tort liability” where State actors violate federal constitutional rights. Heck v. Humphrey, 512 U.S. 477, 483 (1994).

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Bluebook (online)
Jipson v. Workman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jipson-v-workman-kyed-2024.