Loftis v. Conway

CourtDistrict Court, E.D. Oklahoma
DecidedMarch 3, 2025
Docket6:24-cv-00136
StatusUnknown

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

Bluebook
Loftis v. Conway, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

EMBRY JAY LOFTIS,

Plaintiff,

v. Case No. 24-CV-136-RAW-JAR

CODY CONWAY,

Defendant.

OPINION AND ORDER This civil rights action, brought pursuant to 42 U.S.C. § 1983, is before the court on Defendant Cody Conway’s (“Defendant”) Special Appearance and Motion to Dismiss (“Motion”) [Dkt. No. 20]. The court has before it for consideration Plaintiff Embry Jay Loftis’ (“Plaintiff”) Complaint [Dkt. No. 1], Defendant’s Motion [Dkt. No. 20], Plaintiff’s Response [Dkt. No. 26] and Defendant’s Reply [Dkt. No. 27]. At the time of filing his Complaint, Plaintiff was a pro se pretrial detainee incarcerated at the Carter County Detention Center in Ardmore, Oklahoma. Dkt. No. 1 at 2.1 He brings this action under the authority of 42 U.S.C. § 1983, seeking relief for alleged constitutional violations occurring during an April 19, 2023, disturbance at his residence and subsequent arrest. The Defendant is a Chickasaw Lighthouse Police Officer.2

1 The Court’s citations refer to the CM/ECF header pagination.

2 As an initial matter, neither party fully analyzes whether Defendant, a federal tribal officer, can be subject to this litigation. Defendant remarks in a footnote that “the question of sovereign immunity is not reached because the actions at issue were initiated by Ardmore Police Department dispatch and taken under a cross deputization agreement and pursuant to powers granted under Okla. Stat. tit. 21 § 99a(D).” Dkt. No. 27 at 1 n.3. Plaintiff alleged Defendant “act[ed] under the authority of his employ, pursuant to a cross deputization agreement[.]” Dkt. No. 1 at 28. Plaintiff also alleged Defendant was responding to an “Ardmore dispatch … disturbance with weapons call[.]” Id. at 22. The court concludes, under the circumstances alleged, Defendant is characterized I. Background3 Plaintiff alleges on or about the evening of April 19, 2023, Defendant responded to a call, on behalf of the Ardmore Police Department, at Plaintiff’s property.4 Dkt. No. 1 at 5, 22. Defendant was responding initially to a “disturbance with weapons” call which was escalated to a

“shots fired” call while Defendant was en route. Id. at 10, 11, 22, 23. Upon arrival, individuals advised Defendant a male in the white shirt tried to shoot them. Id. at 24-27. Defendant approached the man in a white shirt near a blue car. Id. at 10, 24. “[W]ithout probable cause, provocation or justification” or a “warning,” Defendant deployed a pepperball gun twice, rendering Plaintiff unconscious. Id. at 5, 9, 10. Defendant struck Plaintiff’s shoulder and face. Id. Plaintiff was subsequently taken into custody for public intoxication, and a weapon was not recovered from Plaintiff’s person. Id. at 12, 13, 17. Plaintiff alleges the side effects of the pepperball rounds caused him to be unsteady and Defendant had no grounds to arrest him for public intoxication. See id. at 5, 10-12. Plaintiff also alleges Defendant tampered with witness statements to link, and ultimately arrest, Plaintiff to the crime of pointing a gun when in

fact an individual in a red shirt was the responsible party. See id. at 6, 22-28. Upon booking into

as a “state actor” for purposes of this suit. Loya v. Gutierrez, 350 P.3d 1155, 1157 (N.M. 2015) (“Native–American actors may be subject to a Section 1983 claim if their actions are taken pursuant to state authority. ‘If an individual is possessed of state authority and purports to act under that authority, his action is state action.’” (quoting Williams v. Bd. of Cnty. Comm’rs, 963 P.2d 522, 527 (N.M. 1998)).

3 Plaintiff’s Complaint is eighty-three (83) pages. See Dkt. Nos. 1, 1-1 and 1-2. The court summarizes Plaintiff’s factual allegations which are critical to the court’s analysis.

4 Throughout his Complaint, Plaintiff alleges Defendant did not have authority, as a Chickasaw Lighthorse Officer, to respond to the call on non-native land or arrest Plaintiff, a non-Indian. See, e.g., Dkt. No. 1 at 9. Plaintiff alleges Defendant was acting pursuant to a cross-deputization agreement. Id. at 22. Pursuant to Okla. Stat. tit. 21, § 99a(A), the court concludes Defendant had authority to respond to the Ardmore Police Department’s dispatch call and arrest Plaintiff. the Carter County Detention Center, illegal drugs were found on Plaintiff’s person. Id. at 14. Plaintiff contends these drugs were planted by Defendant. Id. at 6. As a result of the April 19, 2023, encounter, Plaintiff was originally charged in the District Court of Carter County, Case No. CF-2023-144 with two felonies: feloniously pointing a firearm

and trafficking in illegal drugs. Id. at 13; see also Oklahoma v. Loftis, No. CF-2023-144, (Carter Cnty. Dist. Ct.).5 The trafficking in illegal drugs charge was dismissed at the preliminary hearing, and Plaintiff was further charged with felon in possession of a firearm. Dkt. No. 1 at 20; Dkt. No. 1-2 at 22-23; see also Bind Over Information, Loftis, No. CF-2023-144 (Carter Cnty. Dist. Ct. Jan. 18, 2024). In the District Court of Carter County, Case No. CM-2023-285, Plaintiff was charged with three misdemeanors: obstructing an officer, public intoxication and unlawful possession of CDS-Hydrocodone. Dkt. No. 1 at 13; see also Oklahoma v. Loftis, No. CM-2023-285, (Carter Cnty. Dist. Ct.). Concerning the misdemeanor case, the obstructing an officer charge was dismissed, and Plaintiff pled guilty to public intoxication and unlawful possession of CDS- Hydrocodone. Court Minute, Loftis, No. CM-2023-285 (Carter Cnty. Dist. Ct. April 17, 2024). .

Plaintiff alleges Defendant violated Plaintiff’s constitutional rights on April 19, 2023. See Dkt. No. 1. Plaintiff contends Defendant committed the following constitutional violations: 1) Defendant utilized excessive force by deploying his pepperball gun; 2) Defendant falsely arrested Plaintiff for public intoxication; 3) Defendant maliciously prosecuted Plaintiff by planting drugs on Plaintiff; and 4) Defendant falsely arrested and maliciously prosecuted Plaintiff by submitting a probable cause affidavit which relied upon false and/or tampered witness statements thereby

5 The court may consider matters of public record, such as records from Plaintiff’s Carter County criminal cases (CF-2023-144 and CM-2023-285), by taking judicial notice of such documents, without converting the motion to dismiss into a motion for summary judgment. Tal v. Hogan, 453 F.3d 1244, 1264 n.24 (10th Cir. 2006). resulting in the wrong individual being arrested. Dkt. No. 1 at 5-28. Plaintiff also asserts a state law claim for intentional infliction of emotional distress. Id. at 7, 23. Defendant responded to the Complaint by filing a Special Appearance and Motion to Dismiss. Dkt. No. 20. Defendant argues Plaintiff has failed to state a claim upon which relief can

be granted. Id. at 1. Specifically, Defendant contends he possessed probable cause to arrest Plaintiff, his use of force was reasonable, he is entitled to qualified immunity, and Plaintiff’s claims are precluded by the doctrine of judicial estoppel. See id. at 4-9. Defendant also argues Plaintiff’s allegations do not amount to a cognizable claim for intentional infliction of emotional distress. See id. at 9-10. Accordingly, Defendant’s position is that Plaintiff’s entire Complaint must be dismissed. II.

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