Kimbrough v. Hogan

District Court, D. Nebraska·Decided September 25, 2025·No. 8:23-cv-00064·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

QUINTAN J. KIMBROUGH,

Plaintiff, 8:23CV64

vs. MEMORANDUM AND ORDER A. HOGAN III, #2263 City of Omaha Officers; JOHATHAN B. GORDEN, #1927 City of Omaha Officers; MICHAEL J. MYERS, #1307 City of Omaha Officers; and CHRISTOPHER S. MILLER, #2272 City of Omaha Officers;

Defendants.

Plaintiff Quintan J. Kimbrough has sued Defendants—four Omaha police officers— for violating his Fourth Amendment constitutional rights and for state-law battery. Defendants filed a motion to dismiss Plaintiff’s state-law claims pursuant to Federal Rule of Civil Procedure 12(b)(1) and (6), asserting the claims are barred under the Nebraska Political Subdivisions Tort Claims Act (“PSTCA”), Neb. Rev. Stat. § 13-901 et seq. Filing No. 28. Defendants filed a brief in support, Filing No. 29, and Plaintiff filed a response, Filing No. 46, which the Court has considered. For the reasons that follow, Defendants’ motion for partial dismissal will be granted. The Court will also grant Plaintiff’s request for counsel included in his response, Filing No. 46 at 4. I. STANDARD OF REVIEW A. Rule 12(b)(1): Jurisdiction A motion pursuant to Federal Rule of Civil Procedure 12(b)(1) challenges whether the Court has subject matter jurisdiction. The party asserting subject matter jurisdiction bears the burden of proof. Great Rivers Habitat Alliance v. FEMA, 615 F.3d 985, 988 (8th Cir. 2010). A Rule 12(b)(1) motion can be presented as either a “facial” or “factual” challenge. Osborn v. United States, 918 F.2d 724, 729 n.6 (8th Cir.1990). Sovereign immunity is a jurisdictional, threshold matter that is properly addressed under Rule 12(b)(1). See Lors v. Dean, 746 F.3d 857, 861 (8th Cir. 2014); Brown v. United States, 151 F.3d 800, 803–04 (8th Cir. 1998). Here, Defendants' sovereign immunity

defense based on the PSTCA is brought as a facial challenge, and so the Court looks only to the face of the pleadings in considering Defendants’ motion and accepts Plaintiff’s factual allegations as true, just as the Court does in a Rule 12(b)(6) motion, as discussed below. B. Rule 12(b)(6): Failure to State a Claim To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), 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, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “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. Whether a plaintiff is represented by counsel or proceeding pro se, the plaintiff's complaint must allege specific facts sufficient to state a claim. See Martin v. Sargent, 780 F.2d 1334, 1337 (8th Cir. 1985). However, the Court must liberally construe pro se complaints, and these litigants are held to a lesser pleading standard. Topchian v. JP Morgan Chase Bank, N.A., 760 F.3d 843, 849 (8th Cir. 2014). If the essence of an allegation is discernible, although pleaded without “legal nicety,” the Court will construe the complaint in a way that allows the claim to be evaluated within the proper legal framework. Stone v. Harry, 364 F.3d 912, 915 (8th Cir. 2004). II. DISCUSSION As previously summarized in the Court’s Memorandum and Order on initial review of the Amended Complaint, see Filing No. 23, Plaintiff alleges Omaha police officers A.

Hogan III, Johathan B. Gorden, Michael J. Myers, and Christopher S. Miller (collectively “Defendants”) subjected him to excessive force on April 18, 2020, while being transported to the Douglas County Correctional Center following his arrest. Plaintiff alleges he was at least twice dragged from the back of the police cruiser while in handcuffs and was tased, punched, kneed, kicked, choked, and his head slammed into the ground. Plaintiff also alleges Defendants slammed Plaintiff’s head into the car door while “shoving Plaintiff back into the vehicle . . . causing the Plaintiff to lose consciousness.” Filing No. 21 at 5– 6. Plaintiff further alleges that, because he “was already fully compliant with arrest sitting in a police car posing no threat or danger, the Defendants could have only taken this

action with the intent to harm the Plaintiff. Given this consent and compliance, Defendants choice [sic] to intentionally inflict pain by using malicious force . . . .” Id. at 8. Plaintiff alleges Defendants’ use of excessive force caused him to “suffer migraines, headaches, dizziness, and the inability to not walk without pain from nerve damage to his back and neck.” Id. at 1 (spelling corrected). Defendants seek dismissal of Plaintiff’s state-law claims, arguing that they are immune from liability for such claims pursuant to the Nebraska Political Subdivisions Tort Claims Act, Neb. Rev. Stat. § 13-901 to 13-928. The PSTCA “is the exclusive means by which a tort claim may be maintained against a political subdivision or its employees.” Smith v. Iverson, No. 8:19CV298, 2019 WL 4417548, at *17 (D. Neb. Sept. 16, 2019) (quoting Geddes v. York County, 729 N.W.2d 661, 665 (Neb. 2007)); see Neb. Rev. Stat. § 13-902 (“[N]o suit shall be maintained against such political subdivision or its officers, agents, or employees on any tort claim except to the extent, and only to the extent, provided by the [PSTCA].”). “The PSTCA reflects a limited waiver of governmental

immunity,” Geddes, 729 N.W.2d at 665, and its provisions are strictly construed “in favor of the political subdivision and against the waiver of sovereign immunity,” McKenna v. Julian, 763 N.W.2d 384, 390 (Neb. 2000), abrogated on other grounds by Doe v. Bd. of Regents of Univ. of Neb., 788 N.W.2d 264 (Neb. 2010). Defendants are employees of the City of Omaha, which is a political subdivision of the State of Nebraska. See Neb. Rev. Stat. § 13-903(1) (“Political subdivision shall include . . . cities of all classes . . . .”). “Where a claim against an employee of a political subdivision is based upon acts or omissions occurring within the scope of employment, it is governed by the provisions of the PSTCA.” McKenna, 763 N.W.2d at 391. Because Plaintiff alleges Defendants’

Free access — add to your briefcase to read the full text and ask questions with AI

Kimbrough v. Hogan, (D. Neb. 2025).

Kimbrough v. Hogan (Kimbrough v. Hogan) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Chambers v. Pennycook
641 F.3d 898 (Eighth Circuit, 2011)
Martin v. Sargent
780 F.2d 1334 (Eighth Circuit, 1985)
Jonathan Brown v. United States
151 F.3d 800 (Eighth Circuit, 1998)
Varner v. Peterson Farms
371 F.3d 1011 (Eighth Circuit, 2004)
Reavis v. Solminski
551 N.W.2d 528 (Nebraska Supreme Court, 1996)
Keller v. Tavarone
628 N.W.2d 222 (Nebraska Supreme Court, 2001)
Geddes v. York County
729 N.W.2d 661 (Nebraska Supreme Court, 2007)
McKenna v. Julian
763 N.W.2d 384 (Nebraska Supreme Court, 2009)
BERGMAN BY HARRE v. Anderson
411 N.W.2d 336 (Nebraska Supreme Court, 1987)
Weeder v. Central Community College
691 N.W.2d 508 (Nebraska Supreme Court, 2005)
Wise v. Omaha Public Schools
714 N.W.2d 19 (Nebraska Supreme Court, 2006)
Tim Lors v. Jim Dean
746 F.3d 857 (Eighth Circuit, 2014)