LaPena v. Las Vegas Metropolitan Police Department

CourtDistrict Court, D. Nevada
DecidedMarch 22, 2024
Docket2:21-cv-02170
StatusUnknown

This text of LaPena v. Las Vegas Metropolitan Police Department (LaPena v. Las Vegas Metropolitan Police Department) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LaPena v. Las Vegas Metropolitan Police Department, (D. Nev. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * *

7 FRANK LAPENA, Case No. 2:21-CV-2170 JCM (NJK)

8 Plaintiff(s), ORDER

9 v.

10 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, et al., 11 Defendant(s). 12

13 Presently before the court is a motion for partial judgment on the pleadings filed by 14 defendants Clark County, David Schwartz, Clark Peterson, Pamela Weckerly, Marc Digiacomo, 15 Bob Miller, Stewart Bell, David Roger, and Steve Wolfson (collectively, the “Clark County 16 defendants”). (ECF No. 49). Plaintiff Frank Lapena filed a response (ECF No. 85), to which the 17 Clark County defendants replied (ECF No. 90). For the reasons stated below, the court GRANTS 18 in part and DENIES in part the motion for partial judgment on the pleadings. 19 I. Background 20 LaPena alleges a conspiracy spanning decades to wrongfully convict him of murder. He 21 brings over a dozen causes of action and names over a dozen defendants in his amended complaint. 22 (See ECF No. 24). Relevant to the instant motion are the Clark County defendants, which includes 23 Clark County and various attorneys and employees of the Clark County District Attorney’s office. 24 The amended complaint is over 50 pages and includes 164 exhibits—the court summarizes 25 LaPena’s allegations below.1 26

27 1 The court notes that the complaint is riddled with redundant and immaterial allegations. 28 For example, the allegations contained in paragraphs 2, 45, and 188 are largely redundant. Many of the allegations on pages 11 to 12 of the complaint are largely immaterial. And—almost every 1 In 1974, Hilda Krause was violently murdered in her Vegas home by two masked 2 assailants. (Id. at 12). One of the assailants, Gerald Weakland, was identified and arrested after a 3 tip from a confidential informant. (Id. at 13). Weakland had approached the informant some 4 weeks prior in an attempt to recruit him for the murder. (Id.). According to the informant, 5 Weakland did not mention LaPena when discussing the murder plot. (Id. at 14). Weakland 6 likewise did not mention LaPena in his initial statements to the police. (Id.). 7 At some later point, Weakland agreed to cooperate with the state in exchange for leniency. 8 (Id. at 14). Weakland admitted to his role in the murder and, for the first time, named LaPena as 9 the mastermind behind the plot. (Id.). According to Weakland, LaPena and his then-girlfriend 10 hired him to murder Mrs. Krause so that LaPena’s girlfriend could marry Mr. Krause and inherit 11 his estate. (Id. at 14–15). LaPena was not a suspect before this confession. LaPena theorizes that 12 the police were motivated to pin the murder on him to draw attention away from Mr. Kause, who 13 should have been the primary suspect. (Id. at 2, 13). 14 Based on Weakland’s confession, LaPena was arrested, charged, and tried. (Id. at 15). In 15 1977, a jury found LaPena guilty of first-degree murder and sentenced him to life in prison. (Id. 16 at 9, 20). Weakland later recanted his confession. (Id. at 20). The Nevada Supreme Court reversed 17 LaPena’s conviction in 1982 based on that recantation. (Id.). But LaPena was convicted again at 18 a second trial after prosecutors “orchestrated a resurrection” of Weakland’s original confession. 19 (Id. at 21–22). 20 In the decades since then, LaPena has maintained his innocence and attempted to exonerate 21 himself through various legal avenues. (Id. at 9–10). He was eventually paroled and released from 22 custody in 2005, and in 2019, the Nevada Board of Pardons granted him a general pardon. (Id. at 23 11). LaPena was finally issued a Certificate of Innocence in 2021. (Id.; ECF No. 39-10). 24 LaPena now brings suit alleging, in essence, that various members of the Clark County 25 District Attorney’s office, including deputy district attorneys and a string of district attorneys from 26 1978 to 2017, conspired to frame him for the murder of Mrs. Krause and prevent him from 27 exonerating himself. (See id. at 4–9). The court previously dismissed LaPena’s claims against

28 cause of action is brought generally against “all defendants” without sufficient specific allegations thereunder. 1 defendant Melvyn Harmon as barred by prosecutorial immunity and for being insufficiently 2 pleaded. (ECF No. 152). Melvyn Harmon was one of the primary prosecuting attorneys involved 3 in the Krause murder. (See generally ECF No.24). The court now reviews LaPena’s claims against 4 the remaining Clark County defendants. 5 II. Legal Standard 6 “[J]udgment on the pleadings is proper when—taking all the allegations in the non-moving 7 party's pleadings as true—the moving party is entitled to judgment as a matter of law.” Ventress 8 v. Japan Airlines, 486 F.3d 1111, 1114 (9th Cir. 2007) (citation omitted). The nonmoving party’s 9 allegations must be accepted as true while any of the moving party’s allegations that have been 10 denied or contradicted are assumed to be false. MacDonald v. Grace Church Seattle, 457 F.3d 11 1079, 1081 (9th Cir. 2006). 12 The court typically may not consider matters outside the pleadings on a Rule 12(c) motion 13 lest the motion be treated as one for summary judgment. See FED. R. CIV. P. 12(d). But the court 14 can consider matters properly subject to judicial notice under Federal Rule of Evidence 201. Khoja 15 v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1002 (9th Cir. 2018). The court can also consider 16 documents whose contents are merely alleged in a complaint and whose authenticity no party 17 questions. Northstar Fin. Advisors Inc. v. Schwab Invs., 779 F.3d 1036, 1043 (9th Cir. 2015); 18 United States v. Ritchie, 342 F.3d 903, 907–08 (9th Cir. 2003) (holding that courts can consider a 19 document incorporated by reference “if the plaintiff refers extensively to the document or the 20 document forms the basis of the plaintiff's claim”). 21 Motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c) are 22 “functionally identical” to motions to dismiss for failure to state a claim under Rule 12(b)(6). 23 Dworkin v. Hustler Magazine Inc., 867 F.2d 1188, 1192 (9th Cir. 1989). To properly state a claim 24 for relief, the “[f]actual allegations must be enough to rise above the speculative level.”2 Bell 25 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). The complaint must contain sufficient 26 27 28 2 While Rule 8 does not require detailed factual allegations, it demands “more than labels and conclusions” or a “formulaic recitation of the elements of a cause of action.” Id. at 678. 1 factual matter to “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 2 662, 678 (2009) (citation omitted). 3 In Iqbal, the Supreme Court clarified the two-step approach district courts are to apply 4 when considering whether a claim has been sufficiently pled. First, the court must accept as true 5 all well-pled factual allegations in the complaint; however, legal conclusions are not entitled to the 6 assumption of truth. Id. at 678–79. Mere recitals of the elements of a cause of action, supported 7 only by conclusory statements, do not suffice. Id. at 678. 8 Second, the court must consider whether the factual allegations in the complaint allege a 9 plausible claim for relief. Id. at 679.

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LaPena v. Las Vegas Metropolitan Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lapena-v-las-vegas-metropolitan-police-department-nvd-2024.