Karl Shawn Nicholas v. Zachary C. Fratto, in his individual capacity; and Clearfield City, a municipal corporation

CourtDistrict Court, D. Utah
DecidedMarch 11, 2026
Docket1:25-cv-00078
StatusUnknown

This text of Karl Shawn Nicholas v. Zachary C. Fratto, in his individual capacity; and Clearfield City, a municipal corporation (Karl Shawn Nicholas v. Zachary C. Fratto, in his individual capacity; and Clearfield City, a municipal corporation) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Karl Shawn Nicholas v. Zachary C. Fratto, in his individual capacity; and Clearfield City, a municipal corporation, (D. Utah 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

KARL SHAWN NICHOLAS MEMORANDUM DECISION Plaintiff, AND ORDER

vs. Case No. 1:25-CV-00078-DAK-JCB

ZACHARY C. FRATTO, in his individual Judge Dale A. Kimball capacity; and CLEARFIELD CITY, a municipal corporation Magistrate Judge Jared C. Bennett

Defendants.

This matter is before the court on Defendants Zachary C. Fratto’s and Clearfield City’s Motion to Dismiss [ECF No. 18]. On February 5, 2026, the court held a hearing on the motion. At the hearing, Plaintiff was represented by Anna Pitcher Christiansen and John M. Mejia, and Defendant was represented by William S. Helfand and Emily L. Rutter. The court took the motion under advisement. After carefully considering the memoranda filed by the parties and the law and facts pertaining to the motion, the court issues the following Memorandum Decision and Order. BACKGROUND On July 25, 2024, at approximately 3:00 a.m., Plaintiff Karl Nicholas, a mentally handicapped adult male, was walking home alone from Summit Lounge in Layton, Utah. Defendant Officer Zachary Fratto of the Clearfield police department, noticed Nicholas walking through the Legend Hills shopping center and began to follow Nicholas to investigate. Officer Fratto’s body and patrol car cameras recorded the interaction. Officer Fratto pulled alongside Nicholas and Nicholas continued to walk. Officer Fratto got out of his patrol car and began to approach Nicholas on foot at which time Nicholas began to run. Officer Fratto returned to his patrol car and pulled up next to Nicholas, who was no longer running. Officer Fratto questioned Nicholas about why he had been running. Officer Fratto commented that it was strange Nicholas was in the parking lot at such an early morning

hour. Nicholas stated he was running because “you’re following me. And I’m fed up.” Nicholas continued to walk on the public sidewalk. Nicholas crossed the road behind Fratto’s patrol car and outside of a designated crosswalk. Officer Fratto turned his patrol car around and followed Nicholas into an apartment complex parking lot. Officer Fratto exited his patrol car and instructed Nicholas to stop, believing Nicholas had jaywalked. Nicholas stopped. Officer Fratto asked Nicholas for his identification multiple times (twelve times within four minutes) which Nicholas refused to produce and continued to insist he had done nothing wrong. Nicholas informed Officer Fratto that he was walking home from a bar and then threatened to have Officer Fratto fired for harassing him. After approximately four minutes into the encounter, Officer Fratto called for

back-up. Officer Fratto told Nicholas that Nicholas had committed a crime (mistakenly believing Nicholas had jaywalked), and Officer Fratto had a legal right to identify him. He told Nicholas that unless he produced his identification, he would handcuff him and search him for his identification. Nicholas again insisted he had not committed a crime. Officer Fratto instructed Nicholas to put his hands behind his back. Almost simultaneous to the order to place his hands behind his back, Officer Fratto moved toward Nicholas to restrain him. In response, Nicholas raised his hands in front of himself. Officer Fratto grabbed Nicholas’s arm and performed a leg sweep takedown maneuver bringing them both to the ground. After a brief struggle, Officer Fratto handcuffed Nicholas. During the takedown maneuver, Nicholas sustained a bleeding elbow injury and suffers from prolonged pain in his left shoulder. Officer Fratto searched Nicholas’s pockets and removed his wallet, a set of key and some cash money. At this time, two more Clearfield police officers arrived.

Officer Fratto placed Nicholas in the back of his patrol car and recounted the events to the two other officers. At the end of the recitation of the incident, Officer Fratto said, “I figured that his mannerisms were pretty weird. But I did see that he was pretty sweaty, so. I don’t know if he’s necessarily like on drugs or I guess he’s just handicapped.” Compl. ¶ 104. One of the other officers finished Officer Fratto’s sentence by saying “handicapped” at about the same time Officer Fratto did. The second officer made the “handicapped” comment less than two minutes after observing Nicholas. Officer Fratto then released Nicholas with a citation for interfering with a police officer. The Clearfield police department conducted a review of the incident and concluded that Officer Fratto’s use of force was justified. Nicholas filed suit against Officer Fratto in his

individual capacity and Clearfield City for violation of his rights under the Fourth and Fourteenth Amendments and 42 U.S.C § 1983. Nicholas asserts that Officer Fratto violated his constitutional rights and those secured by statute, by unreasonable detention and arrest, search and seizure without probable cause and the use of excessive force. Nicholas alleges that Clearfield City violated these same rights by demonstrating deliberate indifference towards Nicholas’s rights and by its failure to revise policies, supervise or train officers against the use of the leg sweep takedown technique that injured Nicholas. Defendants brought this Motion to Dismiss. STANDARD OF REVIEW

“The court’s function on a Rule 12(b)(6) motion is not to weigh potential evidence that the parties might present at trial, but to assess whether the plaintiff’s complaint alone is legally sufficient to state a claim for which relief may be granted.” Miller v. Glanz, 948 F.2d 1562, 1565 (10th Cir. 1991). “When there are well-pleaded factual allegations [as opposed to legal conclusions], a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. at 678. Allegations must “raise a right to relief above the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). The court is “not bound by conclusory allegations, unwarranted inferences or legal conclusions.” Hackford v. Babbit, 14 F.3d 1457, 1465 (10th Cir. 1994).

DISCUSSION OFFICER FRATTO Officer Fratto asserts he is entitled to qualified immunity and is therefore protected from § 1983 liability. “Qualified Immunity shields federal and state officials from money damages unless a plaintiff pleads facts showing (1) that the official violated a statutory or constitutional

right, and (2) that the right was ‘clearly established’ at the time of the challenged conduct.” Ashcroft v. al-Kidd, 563 U.S.731, 735 (2011). Qualified immunity is an affirmative defense that “creates a presumption that [the defendant is] immune from suit.” Pera v. Baca, 817 F.3d 1198, 1202 (10th Cir. 2016). The burden of proof lies with the plaintiff in establishing both prongs of the standard. Estate of Beauford v. Mesa County, Colorado, 35 F.4th 1248, 1261 (10th Cir. 2022). “If the plaintiff fails to establish either prong of the two-pronged qualified-immunity standard, the defendant prevails on the defense.” Blackmore v. Carlson, 574 F.Supp.3d 1012, 1036 (D. Utah 2021). I. Constitutional violation

The Fourth Amendment protects the “right of the people to be secure in their persons, houses, papers and effects against unreasonable searches and seizures.” U.S. Const. amend. IV. A person is seized only “when the officer, by means of physical force or show of authority, terminates or restrains his freedom of movement.” Brendlin v.

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Karl Shawn Nicholas v. Zachary C. Fratto, in his individual capacity; and Clearfield City, a municipal corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/karl-shawn-nicholas-v-zachary-c-fratto-in-his-individual-capacity-and-utd-2026.