Landon v. Flint, City of

CourtDistrict Court, E.D. Michigan
DecidedMarch 19, 2025
Docket2:24-cv-11876
StatusUnknown

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

Bluebook
Landon v. Flint, City of, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KARTER LANDON,

Plaintiff, Case No. 24-cv-11876 v. Honorable Linda V. Parker

CITY OF FLINT, ET AL.,

Defendants. ___________________________/

OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION (ECF NO. 11) AND GRANTING DEFENDANTS’ MOTION TO DISMISS (ECF NO. 19)

This is Karter Landon’s second lawsuit challenging the City of Flint’s inspection requirements for residential rental properties within its jurisdiction. In the first lawsuit, the Court granted Landon’s motion for a temporary restraining order and preliminary injunction because Flint’s then current Comprehensive Rental Inspection Code did not provide a warrant requirement or offer property owners pre-compliance review. Landon v. City of Flint, No. 16-cv-11061, 2016 WL 7661390 (E.D. Mich. Nov. 30, 2016), adopted in 2017 WL 345854 (E.D. Mich. Jan. 4, 2017). Landon and the City of Flint (hereafter “City”) subsequently settled the case. Stip. of Dismissal, id. (E.D. Mich. May 31, 2018), ECF No. 83. This lawsuit comes after the City amended the relevant city ordinance in September 2020.1 (ECF No. 1 at PageID. 49-53; see also ECF No. 16-5 at PageID. 225.)

In this current action, filed on July 19, 2024, Landon is suing the City and the following City officials in their individual and official capacities: Mayor Sheldon Neeley, Head of Development Emily Doerr, Treasurer and Water

Department Head Amanda Trujillo, Chief Building Inspector Michael Reiter, Chief Financial Officer Phillip Moore, and Chief Attorney William Kim. (See ECF No. 1.) In his Complaint, Landon claims that Defendants have again impeded and threatened to further impede his right to be free from unlimited warrantless

searches through enforcement of the City’s Rental Inspection Program. (See generally id.) He claims violations of his rights under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution and the

“Unconstitutional Conditions” doctrine and tortious interference.2 (Id.)

1 Because of this amendment, Landon is incorrect when he argues that this Court already has found Defendants’ conduct to be unconstitutional. (ECF No. 11 at PageID. 80.) That finding was based on an earlier version of the code, which did not provide a warrant requirement or offer property owners pre-compliance review. As set forth infra, the current version provides for both.

2 The Complaint contains several additional “counts”; however, Landon does not state independent claims in them. (See, e.g., ECF No. 1 at PageID. 28 (Count IV: “Loss of Rents and Other Damages”; Count V: “Nominal and Punitive Damages”).) The matter is presently before the Court on Landon’s motion for a preliminary injunction pursuant to Federal Rule of Civil Procedure 65 (ECF No.

11) and Defendants’ motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1) and (c) (ECF No. 19). In his motion, Landon asks the Court to enjoin enforcement of Section 24-4.3.1 of the City’s Ordinances, which requires property

owners to obtain a Certificate of Compliance before a tenant is allowed to occupy a property. Landon claims that the ordinance is unconstitutional because it mandates an inspection—i.e., a warrantless search—in order to obtain the Certificate of Compliance, and property owners are threatened with losing their right to rent their

properties to tenants or with prosecution if they fail to comply. The motion has been fully briefed. (ECF Nos. 16, 17.) In their motion, Defendants argue that Landon lacks standing and fails to

state a claim upon which relief may be granted. (ECF No. 19.) Defendants also argue that they are entitled to qualified immunity or immunity under Michigan’s Governmental Tort Liability Act (“GTLA”), Mich. Comp. Laws § 691.1401 et seq.. (Id.) The motion also has been fully briefed. (ECF Nos. 20, 21.)

I. Standard of Review A. Preliminary Injunction “A plaintiff seeking a preliminary injunction must establish that he is likely

to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” Enchant Christmas Light Maze & Mrkt. Ltd. v.

Glowco, LLC, 958 F.3d 532, 535-36 (6th Cir. 2020) (quoting Obama for Am. v. Husted, 697 F.3d 423, 428 (6th Cir. 2012)). These factors must be balanced. Union Home Mortg. Corp. v. Cromer, 31 F.4th 356, 365-66 (6th Cir. 2022)

(citation omitted). “But where there is no likelihood of either success on the merits or irreparable harm, an injunction is unwarranted—regardless of the showing on the other factors. Id. (collecting cases). B. Motion to Dismiss

A Rule 12(b)(1) motion challenges the court’s subject matter jurisdiction. “Rule 12(b)(1) motions to dismiss for lack of jurisdiction generally come in two varieties: a facial attack or a factual attack.” Gentek Bldg. Prods., Inc. v. Sherwin-

Williams Co., 491 F.3d 320, 330 (6th Cir. 2007). Defendants raise a factual attack. A factual attack is “not a challenge to the sufficiency of the pleading’s allegation, but a challenge to the factual existence of subject matter jurisdiction.” Id. When a factual attack, also known as a “speaking motion,” raises a factual

controversy, the district court must weigh the conflicting evidence to arrive at the factual predicate that subject-matter does or does not exist.” Id. at 330 (citing Ohio Nat’l Life Ins. Co. v. United States, 922 F.2d 320, 325 (6th Cir. 1990)). “In its

review, the district court has wide discretion to allow affidavits, documents, and even a limited evidentiary hearing to resolve jurisdictional facts.” Id. “[W]hen a defendant produces evidence challenging the factual existence of [subject matter

jurisdiction], a plaintiff must generally prove [subject matter jurisdiction] with evidence, even at the motion-to-dismiss stage.” Harris v. Lexington-Fayette Urban Cnty. Gov’t, 685 F. App’x 470, 472 (6th Cir. 2017) (citing Taylor v. KeyCorp., 680

F.3d 609, 613 (6th Cir. 2012); Superior MRI Servs., Inc. v. All Healthcare Servs., Inc., 778 F.3d 502, 504 (5th Cir. 2015)). A Rule 12(c) motion is subject to the same standard of review as a Rule 12(b)(6) motion to dismiss for failure to state a claim upon which relief can be

granted. Hindel v. Husted, 875 F.3d 344, 346 (6th Cir. 2017) (citing Barany- Snyder v. Weiner, 539 F.3d 327, 332 (6th Cir. 2008)). A Rule 12(b)(6) motion tests the legal sufficiency of the complaint. RMI Titanium Co. v. Westinghouse Elec.

Corp., 78 F.3d 1125, 1134 (6th Cir. 1996). To survive a motion to dismiss, a complaint need not contain “detailed factual allegations,” but it must contain more than “labels and conclusions” or “a formulaic recitation of the elements of a cause of action . . ..” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). A complaint

does not “suffice if it tenders ‘naked assertions’ devoid of ‘further factual enhancement.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 557). As the Supreme Court provided in Iqbal and Twombly, “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as

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

Related

Village of Euclid v. Ambler Realty Co.
272 U.S. 365 (Supreme Court, 1926)
Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Village of Belle Terre v. Boraas
416 U.S. 1 (Supreme Court, 1974)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Moore v. City of East Cleveland
431 U.S. 494 (Supreme Court, 1977)
Parratt v. Taylor
451 U.S. 527 (Supreme Court, 1981)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Kentucky Department of Corrections v. Thompson
490 U.S. 454 (Supreme Court, 1989)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hammond v. Baldwin
866 F.2d 172 (Sixth Circuit, 1989)
Ziss Bros. Construction Co. v. City of Independence, Ohio
439 F. App'x 467 (Sixth Circuit, 2011)
Alan Weiner, D.P.M. v. Klais and Company, Inc.
108 F.3d 86 (Sixth Circuit, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Landon v. Flint, City of, Counsel Stack Legal Research, https://law.counselstack.com/opinion/landon-v-flint-city-of-mied-2025.