Marsden v. Graham

CourtDistrict Court, D. Idaho
DecidedApril 28, 2025
Docket4:23-cv-00547
StatusUnknown

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

Bluebook
Marsden v. Graham, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

DENNIS RAY MARSDEN, Case No. 4:23-cv-00547-BLW-REP

Plaintiff, MEMORANDUM DECISION AND ORDER v.

ZEBULON (ZEB) GRAHAM, in his official and individual capacities as detective and deputy sheriff of the Bonneville County Sheriff’s Department, RANDALL (RANDY) NEAL, in his official and individual capacities as the duly elected Prosecuting Attorney for Bonneville County,

Defendants.

INTRODUCTION Before the Court is a Report and Recommendation filed by United States Magistrate Judge Raymond E. Patricco (Dkt. 58), as well as Defendants’ Motion to Strike (Dkt. 63) and Plaintiff’s Motion for Leave to File Reply (Dkt. 64). For the reasons explained below, Court will adopt the Report and Recommendation in its entirety, deny Defendants’ Motion to Strike as moot, and deny Plaintiff’s Motion for Leave to File Reply. BACKGROUND The facts underlying this dispute are explained in detail in the Report and

Recommendation. See Dkt. 58 at 3-6. In brief, Plaintiff Dennis Ray Marsden paid about $2,000 to make 20,000 door hangers anonymously criticizing three incumbent Idaho Falls city council members ahead of the November 2021 election.

These council members filed complaints, arguing that the door hangers violated Idaho’s Sunshine Act by failing to identify the person(s) responsible for the printing of political literature. Defendant Zebulon Graham, a detective with the Bonneville County Sheriff’s office, began investigating. He eventually requested

an arrest warrant for Marsden for violating Idaho Code § 67-6614A (prohibiting anonymous political speech) and Idaho Code § 67-6611 (requiring a formal filing with the Secretary of State for expenditures over $100 in support or opposition of a

candidate). Defendant Randall Neal, the prosecuting attorney for Bonneville County, refused because § 67-6614A would violate Marsden’s First Amendment rights under McIntyre v. Ohio Election Comm., 514 U.S. 334 (1995), and there was insufficient evidence that Marsden had knowingly violated § 67-6611.

In September 2022, Neal notified Marsden in writing that the expenditure needed to be reported to the Secretary of State pursuant to § 67-6611. Marsden wrote back that he would not comply, and Neal subsequently filed criminal

misdemeanor charges. The case was eventually dismissed because the complaint failed to allege the precise date of the violation, which the court determined was an essential element of the charged offense. Marsden initiated the present action pro

se in December 2023, bringing claims for First Amendment retaliation, malicious prosecution, and conspiracy against Graham and Neal. Both parties moved for summary judgment in May 2024. Over the next nine

months, Marsden filed roughly a dozen additional procedural and evidentiary motions. In February 2025, the Magistrate Judge issued a Report and Recommendation on the cross-motions for summary judgment and two motions by Marsden to amend his complaint. The Magistrate Judge recommended denying

Marsden leave to amend and granting summary judgment for Defendants. Regarding summary judgment, the Magistrate Judge specifically concluded that Neal was entitled to absolute immunity for performing his prosecutorial duties;

Graham was shielded from liability under the independent charging doctrine; and Graham was entitled to qualified immunity because he acted in reliance on a duly enacted statute. Pursuant to Federal Rule of Civil Procedure 72(b)(2), Marsden timely

objected to the Report and Recommendation “as regards Marsden’s § 1983 claims against Graham for violating Marsden’s constitutional right to anonymity.” Pl.’s Objection at 2, Dkt. 60. Defendants filed a response pointing out that Marsden did

not object to summary judgment for Graham based on the independent charging doctrine, summary judgment for Neal based on absolute immunity, or the denial of Marsden’s various other motions.

Marsden then filed a reply arguing that he had not waived the argument about independent charging doctrine and that the Court should not grant summary judgement for Graham. Dkt. 62. Defendants moved to strike the reply as

impermissible under Rule 72(b)(2). Dkt. 63. Marsden responded with a new motion seeking leave to file his reply, contending that the Court has discretion to manage the briefing process and should allow him to correct Defendants’ misrepresentations. All matters are now ripe.

LEGAL STANDARD Any party may challenge a magistrate judge’s proposed recommendation by filing written objections within fourteen days after being served with a copy of the

Report and Recommendation. See 28 U.S.C. § 636(b)(1)(C). The district court must then “make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” Id. The district court may accept, reject, or modify in whole or in part, the

findings and recommendations made by the Magistrate Judge. Id.; see also Fed. R. Civ. P. 72(b). ANALYSIS

The Court begins with Marsden’s request to file a reply to Defendants’ response to his objection. Under Federal Rule of Procedure 72(b) and District of Idaho Local Rule 72.1(b)(2), a party has fourteen days to object to a Magistrate

Judge’s Report and Recommendation. The opposing party then has fourteen days to file a response to that objection. These rules do not allow the objecting party to then file a reply brief.

It is true that the Courts generally has discretion to allow supplemental briefing beyond what is normally permitted. Willnerd v. Sybase, Inc., No. 1:09–cv– 500, 2011 WL 652539, at *1 (D. Idaho Feb. 10, 2011). But even assuming that this applies to Report and Recommendation process under Rule 72, there is no need to

make an exception here. Marsden had a full and fair opportunity to dispute the Magistrate Judge’s recommended disposition. Defendants’ response to Marsden’s objection does not contain any misrepresentations. And although the Court will not

address each assertion in Marsden’s reply, it suffices to say that he completely misunderstands the independent charging doctrine.1 The Court has been quite patient with Marsden’s deluge of procedurally creative filings and will not further

1 The Court will briefly elaborate for Marden’s benefit. Marsden argues that independent charging doctrine only immunizes Graham for the conduct that occurred after Neal independently filed charges. This gets it exactly backwards. “[T]he decision to file a criminal complaint is presumed to result from an independent determination on the part of the prosecutor, and thus, precludes liability for those who participated in the investigation or filed a report that resulted in the initiation of proceedings.” Awabdy v. City of Adelanto, 368 F.3d 1062, 1067 (9th Cir. 2004) (emphasis added). As the Magistrate Judge explained, Marsden had the burden of rebutting this presumption, and he failed to show either that there was no probable cause for the charge or that Graham exerted improper pressure on Neal. Dkt. 58 at 18-20.

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