JONES v. CUMMINGS

CourtDistrict Court, S.D. Indiana
DecidedMay 26, 2020
Docket1:19-cv-02684
StatusUnknown

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

Bluebook
JONES v. CUMMINGS, (S.D. Ind. 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

DAVID JONES, ) ) Plaintiff, ) ) v. ) No. 1:19-cv-02684-SEB-MPB ) RODNEY CUMMINGS, et al. ) ) Defendants. )

ORDER GRANTING DEFENDANTS' MOTION TO DISMISS

This cause is before the Court on Defendants' Motion to Dismiss [Docket No. 7], filed on September 5, 2019, pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. Plaintiff David Jones brings this action against Defendants Rodney Cummings, Steve Koester, and Daniel Kopp, pursuant to 42 U.S.C. § 1983. Mr. Jones alleges that Mr. Cummings, as elected Prosecutor of Madison County, Indiana, adopted an official policy, practice, or custom of ignoring State law and filing untimely amendments of charges against criminal defendants that violated his constitutional Due Process rights. Mr. Jones also alleges a § 1983 claim against Madison County Deputy Prosecutors Koester and Kopp, in their individual capacities, alleging that they committed abuse of process and maliciously prosecuted him when they filed an untimely amendment to add a criminal confinement charge against him and thereafter pursued that charge through conviction and sentencing. For the reasons detailed below, we GRANT Defendants' Motion to Dismiss. Factual Background

In 2005, Mr. Jones was arrested and prosecuted for battery, intimidation, and being an habitual offender. Compl. ¶ 7; Jones v. Zatecky, 917 F.3d 578, 579 (7th Cir. 2019). During the course of Mr. Jones's prosecution, Madison County Deputy Prosecutors Steve Koester and Daniel Kopp moved to amend the charges against him to include a charge of criminal confinement nine days after the "omnibus date" set by the

court, pursuant to Indiana Code § 35-34-1-5 (1982). Compl ¶ 7. Mr. Jones ultimately was convicted of the confinement charge and sentenced to twenty years' imprisonment. Id. Mr. Jones petitioned for habeas relief, which was granted by the Seventh Circuit in

Jones v. Zatecky, 917 F.3d 578, 583 (7th Cir. 2019), on grounds that he was denied effective assistance of counsel based on his attorney's failure to object to the untimely amendment. Compl. ¶ 7. On May 3, 2019, Mr. Jones was released from prison after serving more than half of the twenty-year sentence he received based on the untimely amendment. Id.

Mr. Jones now alleges that Rodney Cummings, the elected Prosecutor in Madison County, was a final policymaker, who adopted an official policy, longstanding practice or custom of deliberately ignoring state law and decisions of the Supreme Court of Indiana that violates individuals' constitutional rights. Id ¶ 11. In particular, Mr. Jones alleges that Mr. Cummings adopted a longstanding practice or custom of ignoring the omnibus deadline for amending charges established by Indiana Code § 35-34-1-5 (1982), as

interpreted by the Indiana Supreme Court in Haak v. State, 695 N.E.2d 944, 951 (Ind. 1998). Compl. ¶ 11. As a result of Mr. Cummings's policy, practice or custom of ignoring the omnibus deadline, Mr. Jones alleges he was "incarcerated for more than a decade and

suffered extreme emotional distress and other physical and mental injury and damages." Id. ¶ 12. In addition, Mr. Jones alleges that deputy prosecutors Koester and Kopp "acted with deliberate indifference" when they "maliciously prosecuted[] and committed abuse

of process against [Mr. Jones] under state law when they made an untimely amendment to add the charge of confinement . . . and pursued that charge through conviction[] and sentencing." Id. ¶ 16. Mr. Jones alleges that the deputy prosecutors "investigated and added the confinement charge . . . [solely] to increase his prison time by decades." Id. ¶ 14.

Defendants moved to dismiss Mr. Jones's complaint on September 5, 2019 on the grounds that: (1) Rodney Cummings "in his official capacity" is not a "person" for purposes of § 1983; and (2) Steve Koester and Daniel Kopp are entitled to absolute

prosecutorial immunity. We address these arguments in turn below. Legal Analysis

I. Standard of Review Defendants have filed their motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6). When considering whether a plaintiff has failed to state a claim upon which relief can be granted, the Court accepts as true all well-pled factual allegations in the complaint and draws all ensuing inferences in favor of the non-movant. Lake v. Neal, 585 F.3d 1059, 1060 (7th Cir. 2009). Nevertheless, the complaint must include "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly,

550 U.S. 544, 570 (2007); see FED. R. CIV. P. 8(a)(2). While the Federal Rules of Civil Procedure "do not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim asserted," Johnson v. City of Shelby, 574 U.S. 10, 11 (2014), the claim asserted must still be "legally cognizable." Balistreri v. Pacifica Police Dep't, 901 F.2d 696, 699 (9th Cir. 1990). If the factual allegations of the complaint, taken

as true, do not support a legally cognizable claim for relief, the Court will grant dismissal. See id. II. Discussion A. Count I

Count I of Mr. Jones’s complaint alleges a claim against Mr. Cummings in his official capacity under 42 U.S.C. § 1983. Essential to Mr. Jones’s claim is the assertion that Mr. Cummings, in his official capacity, qualifies as a "person" under § 1983. See Lett v. Magnant, 965 F.2d 251, 255 (7th Cir. 1992) ("Personhood is an essential element of a § 1983 claim."); Compl. ¶ 5. However, Mr. Cummings argues that Mr. Jones's § 1983

claim against him must be dismissed because he is a state official and it is well- established that "neither a State nor its officials acting in their official capacities are 'persons' under § 1983." Will v. Michigan Dept. of State Police, 491 U.S. 58, 71 (1989). This is the case because a suit against a state official acting in his or her official capacity is in essence a suit against the State itself, and States, unlike municipalities, are entitled to the protection of the Eleventh Amendment. Id at 70-71.

Mr. Jones rejoins that Mr. Cummings, as a county prosecutor, is not a state official. In support of this contention, Plaintiff references the lack of binding precedent establishing that county prosecutors are state officials, arguing that, while there is some authority addressing the issue, the cases are all unpublished, and none address the key

consideration, to wit, the extent to which the county prosecutor is financially independent from the State. We disagree with Mr.

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