MARTIN v. SEABOLT

CourtDistrict Court, M.D. North Carolina
DecidedApril 7, 2025
Docket1:21-cv-00906
StatusUnknown

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

Bluebook
MARTIN v. SEABOLT, (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA KA’LAH (KALAH) MARTIN, ) ) Plaintiff, ) ) v. ) 1:21cv906 ) GREGORY SEABOLT, et al., ) ) Defendants. ) MEMORANDUM OPINION AND ORDER This case comes before the Court on Plaintiff’s Motion for Reconsideration and a New Trial (Docket Entry 74) (the “Second Reconsideration Motion”). For the reasons that follow, the Court will deny the Second Reconsideration Motion.1 BACKGROUND Alleging state and federal claims related to an incident on February 28, 2019, Ka’lah (Kalah) Martin (the “Plaintiff”) sued various employees of the Randolph County Sheriff’s Office, including Deputies Travis Short, Kyle Gabby, and Jeremiah Harrelson (collectively, the “Defendants”), as well as Sheriff Gregory Seabolt. (See, e.g., Docket Entry 1, ¶¶ 2-4, 32.) Of relevance here, Plaintiff sued Sheriff Seabolt solely in his official capacity, but sued Defendants in both their official and individual 1 Pursuant to the parties’ consent, now-Senior United States District Judge Loretta C. Biggs referred this case to the undersigned United States Magistrate Judge for all proceedings. (See Docket Entry 15 at 1.) capacities. (See, e.g., id. at 1.)* After the parties engaged in discovery (see, e.g., Docket Entry 16 at 2 (describing certain discovery efforts)), the defense “move[d] for summary judgment on all claims asserted in Plaintiff[’s operative] Complaint” (Docket Entry 30 (the “Summary Judgment Motion”) at 1). Plaintiff opposed the Summary Judgment Motion, but did not file her own motion for summary judgment. (See Docket Entries dated Oct. 11, 2022, to Apr. 25, 2023.) The Court granted in part the Summary Judgment Motion, dismissing all official-capacity claims and allowing only Plaintiff’s state-law assault and battery and Section 1983 excessive force claims against Defendants in their individual capacities to proceed. (See, e.g., Docket Entry 35 (the “Summary Judgment Opinion”) at 67; see also id. at 68 (explaining that, “as to all other claims and all other [d]lefendants, the Court will enter summary judgment against Plaintiff”).) As the Summary Judgment Opinion noted, Plaintiff’s official-capacity claims failed because, inter alia, “Plaintiff has not presented evidence sufficient to indicate the existence of a policy allowing for [the challenged conduct]” (id. at 20; see also id. at 24, 43, 48) and, as Plaintiff conceded, she “failed to allege or present any evidence that Defendants waived sovereign immunity through the

2 Docket Entry page citations utilize the CM/ECF footer’s pagination.

purchase of liability insurance” (id. at 59 (internal quotation marks omitted)), thereby defeating Plaintiff’s state-law official- capacity tort claims (see id. at 58-59). However, genuine issues of material fact precluded resolution, at the summary judgment stage, of Plaintiff’s individual-capacity assault, battery, and excessive force claims against Defendants, including regarding the applicability of qualified immunity. (See id. at 25-42, 58-60.) Plaintiff subsequently moved, purportedly pursuant to Rule 60 of the Federal Rules of Civil Procedure (the “Rules”), for reinstatement of her official-capacity claims. (Docket Entry 39 (the “First Reconsideration Motion”) at 1-2.) The First Reconsideration Motion based its reconsideration request primarily on the fact that, nearly two years after the traffic stop involving Plaintiff, Deputies Gabby and Short participated in another traffic stop, this time of an individual named Justin Collins, using a patrol vehicle equipped with a dashboard camera, a situation that, in Plaintiff’s view, establishes the existence of video camera footage of the earlier incident involving Plaintiff. (See generally Docket Entry 41; see also Docket Entry 43 (the

“Reconsideration Opinion”) at 10 (explaining that, “[a]ccording to Plaintiff, the fact that [Deputy] Gabby’s patrol car contained video cameras when he conducted a traffic stop of Collins in February 2021 proves that the defense lied when it said that no video of Plaintiff’s stop in February 2019 exists”).) Defendants 3 opposed the First Reconsideration Motion. (See Docket Entry 42 (the “Original Opposition”) at 1-10.) For myriad reasons, the Court denied the First Reconsideration Motion. (See Docket Entry 43 at 1-21.) To begin, as the Reconsideration Opinion observed, “Plaintiff failed to reply to the [Original] Opposition” (id. at 8), thereby conceding its “multiple arguments for denial of the [First Reconsideration] Motion” (id.) and “warranting denial of the [First Reconsideration] Motion on this basis alone” (id. at 9). The Reconsideration Opinion also explained that, “to the extent that Plaintiff suggests the Collins incident renders manifestly unjust the dismissal of all official-capacity claims, allegedly allowing [the d]efendants to escape accountability for their actions, Plaintiff has not met her high burden of showing that the [Summary Judgment] Opinion was clearly erroneous and would work a manifest injustice.” (Id. at 13-14 (brackets and internal quotation marks omitted).) Further, the Reconsideration Opinion noted, “the proffered evidence does not support Plaintiff’s contentions” (id. at 10), as, inter alia, the fact that, while on interdiction duty in 2021, [Deputy] Gabby’s patrol vehicle contained video cameras (see, e.g., Docket Entry 41-1 at 1-2) does not contradict Sheriff Seabolt’s sworn statement (1) that “[t]here is no camera footage of [Plaintiff’s] February 28, 2019, traffic stop” (Docket Entry 41-3, ¶ 5); (2) that, “[i]n 2019, the Randolph County Sheriff’s Office patrol cars were not equipped with dashboard cameras, except for those patrol cars used by the Randolph County interdiction team” (id., ¶ 6); (3) that, “[a]t the time of the incident, Randolph County patrol vehicles used by the interdiction team were the only vehicles with in-car 4 cameras” (id., @ 9); (4) that, as of April 3, 2023, “Randolph County Sheriff’s Office patrol vehicles [we]re still not outfitted with in-car cameras, except for those used by the interdiction team” (id., 7 12); and (5) that, “[i]n 2019, the Randolph County Sheriff’s Office patrol deputies were not equipped with body-worn cameras” (id., Gq 7). (Docket Entry 43 at 10-11 (emphasis and certain brackets in original).) Meanwhile, Defendants pursued an interlocutory appeal of the Summary Judgment Opinion’s denial of qualified immunity. (See Docket Entry 44 at 3.) The United States Court of Appeals for the Fourth Circuit affirmed the denial of qualified immunity, agreeing that material factual disputes in the then-existing record precluded an award of qualified immunity to Defendants at the summary judgment stage. (See id. at 3-10.) The matter then proceeded to a three-day jury trial on Plaintiff’s individual- capacity assault, battery, and excessive force claims against Defendants. (See Docket Entries dated Nov. 18, 2024, to Nov. 20, 2024.) Defendants, Sheriff Seabolt, and Plaintiff each testified during the trial. (See Docket Entry 67 at 1.) The jury promptly found that Plaintiff failed to prove her claims against Defendants (see Docket Entry 69 at 1-6), after which the Court entered judgment in favor of the various defendants in the matter (see Docket Entry 72 (the “Judgment”) at 1-2). Four days later, Plaintiff filed the Second Reconsideration Motion (see Docket Entries dated Nov. 25, 2024), moving

under Rule 59(1)(b)(d)(e) . . ., as well as Rule 60(5)(6); 42 U.S.C. §1983

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Bluebook (online)
MARTIN v. SEABOLT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-seabolt-ncmd-2025.