Keshia Douglas v. Albany Police Department and Albany County District Attorney

CourtDistrict Court, N.D. New York
DecidedMarch 9, 2026
Docket1:24-cv-00807
StatusUnknown

This text of Keshia Douglas v. Albany Police Department and Albany County District Attorney (Keshia Douglas v. Albany Police Department and Albany County District Attorney) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keshia Douglas v. Albany Police Department and Albany County District Attorney, (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ____________________________________________

KESHIA DOUGLAS,

Plaintiff, vs. 1:24-CV-807 (MAD/PJE) ALBANY POLICE DEPARTMENT and ALBANY COUNTY DISTRICT ATTORNEY,

Defendants. ____________________________________________

APPEARANCES: OF COUNSEL:

KESHIA DOUGLAS PO Box 3812 Albany, New York 1220 Plaintiff, pro se

THE REHFUSS LAW FIRM, P.C. STEPHEN J. REHFUSS, ESQ. 40 British American Boulevard Latham, New York 12110 Attorneys for Defendants Albany Police Department and Albany County District Attorney

ALBANY COUNTY DEPARTMENT CHRISTINE FERNANDEZ, ESQ. OF LAW 112 State Street Albany, New York 12207 Attorneys for Defendants Albany Police Department and Albany County District Attorney

LAW OFFICE OF MEGAN B. MEGAN B. VAN AKEN, ESQ. VAN AKEN 69 State Street, Suite 1200g Albany, NY 12207 Attorney for Defendant Albany County District Attorney

Mae A. D'Agostino, U.S. District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION On June 23, 2024, Plaintiff Keshia Douglas ("Plaintiff") filed a complaint, pro se, against the Albany Police Department ("APD") and Albany County District Attorney ("District Attorney's Office") (collectively, "Defendants") alleging violations of her Fourteenth Amendment Due Process Rights. See Dkt. No. 1. Plaintiff seeks monetary damages and a declaratory judgment. See id. On April 25, 2025, Defendants filed separate motions to dismiss pursuant to Federal Rule of Civil Procedure 12(c). See Dkt. Nos. 55, 56. Plaintiff opposed each motion and Defendants replied. See Dkt. Nos. 57, 59, 60, 61. With the permission of the Court, Plaintiff filed a sur-reply. See Dkt. Nos. 62, 63, 64.1 For the following reasons, Defendants' motions to dismiss are granted. II. BACKGROUND

In early September 2023, Plaintiff's vehicle was hit by gunfire while she was leaving 212 Market in Albany, New York. See Dkt. No. 1 at ¶ 7. Plaintiff immediately reported the incident to APD because she believed the gunfire could be related to "someone being shot and killed blocks away from where her vehicle was shot." Id. at ¶ 8. Shortly thereafter, APD took custody of Plaintiff's vehicle with her permission. Id. at ¶ 9. Plaintiff alleges that after she consented to the seizure, APD served her with a search warrant permitting officers to "search her Vehicle and seize any evidence found as outlined in the search warrant." Id. Plaintiff notes that she is "neither a suspect nor a party to any criminal proceeding regarding the homicide." Id. at ¶ 12.

1 On September 2, 2025, Plaintiff filed a motion to expedite the Court's decision. See Dkt. No. 65. Plaintiff maintains that APD is still in possession of her vehicle and has continuously possessed it since September 3, 2023. See id. at ¶ 13. Plaintiff further alleges that APD's continued possession of her vehicle is "causing significant financial hardship and emotional distress to [her] and her family." Id. Prior to commencing this action, Plaintiff filed a lawsuit against only APD in New York State Supreme Court, Albany County, pursuant to Article 71 of the Civil Practice Law and Rules. See N.Y. C.P.L.R. 7101. She sought a writ of replevin compelling APD to return her vehicle. See Dkt. No. 1 at 11-15. Albany County Supreme Court declined to issue the writ. See id. at 89-92. Plaintiff then commenced this action

pursuant to 42 U.S.C § 1983, alleging that Defendants violated her Fourteenth Amendment right to procedural due process by continuing to retain possession of her vehicle. See id. at 4- 5. Plaintiff also seeks a declaratory judgment pursuant to 28 U.S.C §§ 2201 and 2202 stating that Defendants' actions violated her Plaintiff’s Fourteenth Amendment due process rights. Id. at 5. III. DISCUSSION A. Standard of Review Rule 12(c) of the Federal Rules of Civil Procedure provides that "after the pleadings are closed—but early enough not to delay trial—a party may move for judgment on the pleadings." FED. R. CIV. P. 12(c). When a party makes a Rule 12(c) motion, the court applies the

same standard as when a party files a Rule 12(b)(6) motion. See Hayden v. Paterson, 594 F.3d 150, 160 (2d Cir. 2010) (citation omitted). A motion to dismiss for failure to state a claim pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure tests the legal sufficiency of the party's claim for relief. See Patane v. Clark, 508 F.3d 106, 111-12 (2d Cir. 2007) (citation omitted). In considering the legal sufficiency of a complaint, a court must accept as true all well-pleaded facts in the pleading and draw all reasonable inferences in the pleader's favor. See ATSI Commc'ns, Inc. v. Shaar Fund, Ltd., 493 F.3d 87, 98 (2d Cir. 2007) (citation omitted). This presumption of truth, however, does not extend to legal conclusions. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation omitted). Although a court's review of a motion to dismiss is generally limited to the facts presented in the pleading, the court may consider documents that are "integral" to that pleading, even if they are neither physically attached to, nor incorporated by reference into, the pleading. See Mangiafico v. Blumenthal, 471 F.3d 391, 398 (2d Cir. 2006) (quoting Chambers v. Time Warner, Inc., 282 F.3d 147, 152-53 (2d Cir. 2002)).

To survive a motion to dismiss, a party need only plead "a short and plain statement of the claim," see Fed. R. Civ. P. 8(a)(2), with sufficient factual "heft to 'sho[w] that the pleader is entitled to relief[,]'" Bell Atl. Corp. v. Twombly, 550 U.S. 544, 557 (2007) (quotation omitted). Under this standard, the pleading's "[f]actual allegations must be enough to raise a right of relief above the speculative level," see id. at 555 (citation omitted), and present claims that are "plausible on [their] face," id. at 570. "The plausibility standard is not akin to a 'probability requirement,' but it asks for more than a sheer possibility that a defendant has acted unlawfully." Iqbal, 556 U.S. at 678 (citation omitted). "Where a complaint pleads facts that are 'merely consistent with' a defendant's liability, it 'stops short of the line between possibility and

plausibility of "entitlement to relief."' Id. (quoting Twombly, 550 U.S. at 557). Ultimately, "when the allegations in a complaint, however true, could not raise a claim of entitlement to relief," Twombly, 550 U.S. at 558, or where a plaintiff has "not nudged [its] claims across the line from conceivable to plausible, the[ ] complaint must be dismissed[,]" id. at 570. Additionally, courts must afford pro se plaintiffs "special solicitude." See Ruotolo v. I.R.S., 28 F.3d 6, 8 (2d Cir. 1994) (citing Graham v.

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