McKinnon v. Schmidt

CourtDistrict Court, D. Maryland
DecidedJuly 12, 2022
Docket1:21-cv-01828
StatusUnknown

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

Bluebook
McKinnon v. Schmidt, (D. Md. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

WILLIE ORLANDO McKINNON, *

Plaintiff, *

v. * Civil Action No. PX-21-1828

COUNTY EXECUTIVE, et al., *

Defendants. * *** MEMORANDUM OPINION

Willie Orlando McKinnon brings this civil action against the Montgomery County Executive Marc Elrich and Officer Michael Schmidt, contending that Defendants violated his constitutional rights to be free from excessive force during his arrest on January 30, 2021. ECF No. 6-1. Defendants move to dismiss the action or alternatively to stay this case pending resolution of McKinnon’s state criminal matter. ECF No. 20. For the following reasons, the Court dismisses all claims except for the excessive force allegation against Defendant Schmidt, which will be stayed until the conclusion of the criminal prosecution. I. Background The Court construes the complaint facts most favorably to McKinnon as the non-moving party. On January 30, 2021 at approximately 1:45 a.m., McKinnon exited a store and entered a car driven by Emmanuel Harried. ECF No. 6-1 at 1. Members of Montgomery County Police Department’s Special Assignment Team (“SAT”) immediately surrounded the car to arrest the two men. Id. Officers demanded that McKinnon raise his hands and place them on the car window. Id. Officer Schmidt next used a metal bar to shatter the car windows, striking McKinnon’s right elbow twice in the process. Id. Officers ultimately arrested McKinnon and charged him with theft, armed robbery, and a variety of related offenses.1 During post-arrest questioning, McKinnon told officers that his elbow was hurting, but none attended to his complaints. ECF No. 6-1 at 2. Ultimately, McKinnon’s injuries were

serious enough that he lost function in his right hand, partially paralyzing one of his fingers and causing pain in his hand and wrist. Id. Although McKinnon avers that the criminal charges had been “dropped,” id. at 2, court records reflect that the criminal trial is set for January 3, 2023. See Case No. 138299C, Montgomery County Circuit Court, https://casesearch.courts.state.md.us/casesearch/inquiryDetail.jis?caseId=138299C&loc=68&det ailLoc=ODYCRIM (last visited July 6, 2022). II. Legal Standard Defendants move to dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. In reviewing the motion, the Court accepts the well-pleaded allegations as true and in the light most favorable to the plaintiff. Bell Atl. Corp. v. Twombly, 550

U.S. 544, 555 (2007). “However, conclusory statements or a ‘formulaic recitation of the elements of a cause of action will not [suffice].’” EEOC v. Performance Food Grp., Inc., 16 F. Supp. 3d 584, 588 (D. Md. 2014) (quoting Twombly, 550 U.S. at 555). “Factual allegations must be enough to raise a right to relief above a speculative level.” Twombly, 550 U.S. at 555. “‘[N]aked assertions’ of wrongdoing necessitate some ‘factual enhancement’ within the complaint to cross ‘the line between possibility and plausibility of entitlement to relief.’” Francis v. Giacomelli, 588 F.3d 186, 193 (4th Cir. 2009) (quoting Twombly, 550 U.S. at 557).

1 See Case No. 138299C, Montgomery County Circuit Court, https://casesearch.courts.state.md.us/casesearch/inquiryDetail.jis?caseId=138299C&loc=68&detailLoc=ODYCRIM (last visited July 6, 2022). Although pro se pleadings are construed generously to allow for the development of a potentially meritorious case, Hughes v. Rowe, 449 U.S. 5, 9 (1980), courts cannot ignore a clear failure to allege facts setting forth a cognizable claim. See Weller v. Dep’t of Soc. Servs., 901 F.2d 387, 391 (4th Cir. 1990) (“The ‘special judicial solicitude’ with which a district court should view

such pro se complaints does not transform the court into an advocate. Only those questions which are squarely presented to a court may properly be addressed.”) (internal citation omitted)). “A court considering a motion to dismiss can choose to begin by identifying pleadings that, because they are not more than conclusions, are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 665 (2009).2 III. Analysis A. County Executive Marc Elrich Defendants move to Dismiss as a defendant County Executive Marc Elrich because the complaint does not aver any acts or omissions on Elrich’s part. McKinnon responds that he had sued Elrich in his supervisory capacity only, and on a respondeat superior liability theory.

However, it is well-settled that the doctrine of respondeat superior does not apply to claims brought pursuant to 42 U.S.C. § 1983. See Love-Lane v. Martin, 355 F.3d 766, 782 (4th Cir. 2004) (no respondeat superior liability under § 1983). Liability of supervisory officials in this context “is not based on ordinary principles of respondeat superior, but rather is premised on ‘a recognition that supervisory indifference or tacit authorization of subordinates’ misconduct may be a causative

2 By separate correspondence, McKinnon attempts to add claims of excessive force, false imprisonment, illegal search and seizure and racial profiling, but includes no factual support. ECF Nos. 10-11, 16. Because McKinnon fails to demonstrate how these claims could survive challenge, allowing amendment would be futile. See Katyle v. Penn Nat. Gaming, Inc. 637 F.3d 462, 471 (4th Cir. 2011), citing United States ex rel. Wilson v. Kellogg Brown & Root, Inc., 525 F.3d 370, 376 (4th Cir. 2008) (“[A] district court may deny leave if amending the complaint would be futile—that is, if the proposed amended complaint fails to satisfy the requirements of the federal rules.”). factor in the constitutional injuries they inflict on those committed to their care.’” Baynard v. Malone, 268 F.3d 228, 235 (4th Cir. 2001) (quoting Slakan v. Porter, 737 F.2d 368, 372 (4th Cir. 1984)); see also Shaw v. Stroud, 13 F.3d 791, 799 (4th Cir. 1994). McKinnon’s Amended Complaint fails to plead any facts that plausibly support a claim of

supervisory liability against Elrich. Moreover, even if the Court assumes that McKinnon wanted to sue Montgomery County through its Chief Executive, nothing in the Amended Complaint makes plausible that any alleged constitutional violations stemmed from any County policy, custom, or practice. See Monell v. Dep’t of Social Servs. of N.Y., 436 U.S. 658, 691, 694 (1978). Thus, Elrich must be dismissed from this suit. B. Officer Michael Schmidt As to Officer Schmidt, the Amended Complaint challenges that he exercised excessive force during McKinnon’s arrest, inflicted cruel and unusual punishment, and violated McKinnon’s equal protection rights. ECF No. 6-1. The Court considers each allegation separately. 1. Equal Protection Claim

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

Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Hughes v. Rowe
449 U.S. 5 (Supreme Court, 1980)
City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
Pennzoil Co. v. Texaco Inc.
481 U.S. 1 (Supreme Court, 1987)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Katyle v. Penn National Gaming, Inc.
637 F.3d 462 (Fourth Circuit, 2011)
Laurel Sand & Gravel, Inc. v. Wilson
519 F.3d 156 (Fourth Circuit, 2008)
Francis v. Giacomelli
588 F.3d 186 (Fourth Circuit, 2009)
United States v. State of South Carolina
720 F.3d 518 (Fourth Circuit, 2013)
Williams v. Lubin
516 F. Supp. 2d 535 (D. Maryland, 2007)
Baynard v. Malone
268 F.3d 228 (Fourth Circuit, 2001)
Love-Lane v. Martin
355 F.3d 766 (Fourth Circuit, 2004)
Shaw v. Stroud
13 F.3d 791 (Fourth Circuit, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
McKinnon v. Schmidt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinnon-v-schmidt-mdd-2022.