Little v. City of Nampa

District Court, D. Idaho·Decided May 30, 2025·No. 1:24-cv-00258·Unknown

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

SHANNON LITTLE and GAYLE F.

LITTLE, individually and as husband and Case No. 1:24-cv-00258-DCN wife,

MEMORANDUM DECISION AND Plaintiffs, ORDER ON MOTION FOR 12(b)(6) DISMISSAL OF FEDERAL CLAIMS v.

CITY OF NAMPA, CHIEF JOE HUFF, Chief of Police of Nampa Police Department, and DETECTIVE ELLOUISE SCOTT, individually and in her official capacity as a law enforcement officer of Nampa Police Department,

Defendants.

I. INTRODUCTION The Court has before it a Motion to Dismiss filed by the City of Nampa, Chief Joe Huff, and Detective Ellouise Scott (“the Defendants”). The motion is fully briefed and at issue. Having reviewed the record and briefs, the Court finds that the facts and legal arguments are adequately presented. ccordingly, in the interest of avoiding further delay, and because the Court finds that the decisional process would not be significantly aided by oral argument, the Court will decide the motion without oral argument. Dist. Idaho Loc. Civ. Rule 7.1(d)(1)(B). Upon review, and for the reasons set forth below, the Court GRANTS Defendants’ Motion to Dismiss (Dkt. 11) the federal claims. II. BACKGROUND Plaintiff Gayle Little claims that Defendant Scott, a law enforcement officer with

the Nampa Police Department, violated her privacy by improperly providing information to the Idaho Health and Welfare Foster System (IDHWF) that caused her to lose her license and employment as a foster parent. Plaintiff brought federal claims of violation of due process, unreasonable search and seizures, and right to free speech.1 The information came from Scott’s review of the contents of Little’s cell phone, which Little had voluntarily given to the Nampa Police Department for review of messages

between Little and another party. See Complaint, Dkt 1, at ¶ 15. Detective Koho, a digital forensics investigator, extracted messages off Little’s cell phone and provided them or a report of them to Scott for review. Dkt. 1, at ¶ ¶ 16 &17. Scott then contacted IDHWF to report child abuse concerns involving Little and foster children. Scott also gave IDHWF copies and/or original screenshots from Little’s phone of conversations with friends and

her brother. On April 12, 2023, IDHWF informed Little that her foster care license was revoked. Dkt. 1, at ¶ 24. III. LEGAL STANDARD A motion to dismiss for failure to state a claim under Rule 12(b)(6) challenges the

legal sufficiency of the claims stated in the complaint. Conservation Force v. Salazar, 646 F.3d 1240, 1242 (9th Cir. 2011). To sufficiently state a claim for relief and survive a

1 Defendants were granted summary judgment on all State law claims because Little failed to file a Notice of Tort Claim as required by State law. 12(b)(6) motion, the pleading “does not need detailed factual allegations;” however, the “[f]actual allegations must be enough to raise a right to relief above the speculative level.”

Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). Mere “labels and conclusions [or] a formulaic recitation of the elements of a cause of action will not do.” Id. Rather, there must be “enough facts to state a claim to relief that is plausible on its face.” Id. at 570. 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 556. The plausibility standard is not akin to a “probability requirement,” but does require more

than a sheer possibility that a defendant acted unlawfully. Id. In Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009), the Supreme Court identified two “working principles” that underlie Twombly. First, although a court must accept as true all factual allegations in a complaint when ruling on a motion to dismiss, the court need not accept unreasonable inferences or legal conclusions as true. Id. “Rule 8 marks a notable

and generous departure from the hyper-technical, code-pleading regime of a prior era, but it does not unlock the doors of discovery for a plaintiff armed with nothing more than conclusions.” Id. at 678–79. Second, only a complaint that states a plausible claim for relief will survive a motion to dismiss. Id. at 679. In light of Twombly and Iqbal, the Ninth Circuit has summarized the governing

standard as follows: “In sum, for a complaint to survive a motion to dismiss, the non- conclusory factual content, and reasonable inferences from that content, must be plausibly suggestive of a claim entitling the plaintiff to relief.” Moss v. U.S. Secret Serv., 572 F.3d 962, 969 (9th Cir. 2009). Apart from factual insufficiency, a complaint is also subject to dismissal under Rule 12(b)(6) where it lacks a cognizable legal theory, Balistreri v. Pacifica Police Dep't, 901 F.2d 696, 699 (9th Cir. 1988), or where the allegations on their

face show that relief is barred for a legal reason. Jones v. Bock, 549 U.S. 199, 215 (2007). IV. ANALYSIS In responding to the Motion to Dismiss, Plaintiffs agree that Plaintiff Shannon Little does not have standing pursuant to the claims in Plaintiffs’ Complaint and ask that Shannon be dismissed as a Plaintiff. Dkt. 29. Therefore, Shannon Little is dismissed from this case. As to Gayle Little, Defendants argue that Plaintiff lumped all Defendants together

without differentiating among them, which is a failure to adequately state a claim. Additionally, Defendants argue that no clearly established right to privacy exists in the context of phone information contained on a cell phone voluntarily given to the police, and no clearly established violation occurred when police gave that information to licensing authorities. According to Defendants, this also is a failure to adequately state a claim.

Plaintiff argues that, “While inartfully articulated, Plaintiff’s complaint plausibly alleges that the City of Nampa and Chief Joe Huff failed to properly train or supervise Scott.” Dkt. 29. Plaintiff further argues that the Complaint adequately addresses both procedural and substantive due process. The Court will address the argument regarding the compounding of claims against

all defendants, followed by the claims against the City and Sheriff, and then the claims against Scott. The Court will then end with Plaintiff’s request to amend her Complaint. A. Assertion of Constitutional Violations in the Collective. The rule of law in this type of case makes it clear that collective assertions are not allowed. For example, in Ashcroft v. Iqbal, 556 U.S. 662 (2009), the Supreme Court stated, “implied causes of action are disfavored.” Id. at 676. Even more strongly, the Court stated,

“Because vicarious liability is inapplicable to Bivens and § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.” Id. at 676. A careful review of the Complaint shows that Little alleges Detective Koho extracted information from a cell phone Little gave to Nampa Police. Investigator Scott then reviewed that information and contacted IDHWF to report child abuse concerns. Little

further alleges that Scott told IDHWF Little was using drugs in her home with children present.

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

Little v. City of Nampa, (D. Idaho 2025).

Little v. City of Nampa (Little v. City of Nampa) — 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)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Conservation Force v. Salazar
646 F.3d 1240 (Ninth Circuit, 2011)
Edward G. Eldridge v. Sherman Block
832 F.2d 1132 (Ninth Circuit, 1987)
Harris v. Amgen, Inc.
573 F.3d 728 (Ninth Circuit, 2009)
Moss v. U.S. Secret Service
572 F.3d 962 (Ninth Circuit, 2009)
Neil O'Brien v. John Welty
818 F.3d 920 (Ninth Circuit, 2016)
Yassir Fazaga v. Fbi
916 F.3d 1202 (Ninth Circuit, 2019)