McWhorter v. Department of Corrections

District Court, W.D. Washington·Decided October 21, 2024·No. 3:24-cv-05146·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA CASE NO. 3:24-cv-05146-KKE-GJL Plaintiff, v. REPORT AND RECOMMENDATION DEPARTMENT OF CORRECTIONS, Noting Date: November 5, 2024 et al., Defendants.

The District Court has referred this 42 U.S.C. § 1983 prisoner civil rights action to United States Magistrate Judge Grady J. Leupold. Currently before the Court is Plaintiff John T. McWhorter’s Amended Complaint. Dkt. 14. Upon review, the undersigned finds the Amended Complaint remains deficient in a manner not likely to be cured through further amendment. It is therefore recommended this action be DISMISSED for failure to cure pleading deficiencies and for other reasons outlined below. Plaintiff is housed at Stafford Creek Corrections Center, where he is serving a sentence on a 1997 state-court conviction for first and second-degree rape in addition to first-degree robbery. See State v. McWhorter, Kitsap County Superior Court, Docket No: 97-1-00660-9; see also State v. McWhorter, 24 Wash. App. 2d 1022, 2022 WL 16758567 (2022), review granted, decision rev’d by 535 P.3d 880 (Wash. 2023). He initiated this action on February 22, 2024, alleging numerous constitutional violations flowing from his state-court conviction and sentence.

Dkt. 1-1. A. Dismissal of Initial Complaint with the Opportunity to Amend Plaintiff brought a medley of constitutional claims in his Initial Complaint against the Department of Corrections (“DOC”), DOC employees, the Indeterminate Sentence Review Board (“ISRB”), ISRB employees, Washington State Attorney General Robert Ferguson, and Assistant Attorney General John Dittman. Dkt. 1-1, at 2, 5–11. Plaintiff organized his claims into three Counts for relief: Count I alleged violations of the Fourth and Fifth Amendment to the United States Constitution, Count II alleged violations of the Eighth Amendment, and Count III alleged violations of the Thirteenth Amendment. Id. at 7–11. After screening the Initial Complaint, the undersigned recommended dismissal with

prejudice. Dkt. 5. This recommendation was based on the finding that each Count in the Initial Complaint rested on a core allegation that was “a demonstrable falsehood,” so the entire Initial Complaint was deficient in a manner not curable through amendment. Id. at 4. Specifically, the undersigned found that “all of Plaintiff’s claims and allegations are based on his mistaken belief that the Kitsap County Superior Court [‘Superior Court’] vacated his sentence and judgment on April 28, 2021, and, as a result, [each Count asserts that] DOC employees acted unlawfully when they refused to release him from custody.” Id. at 4 (internal citations omitted) (emphasis added). The District Court adopted, in part, the undersigned’s recommendation. The District Court agreed that Plaintiff’s state-court judgment was not vacated and so his “core allegation”

that he remained in custody without a valid judgment was “without merit.” Dkt. 9 at 4. As such, the District Court found nonviable and dismissed all Plaintiff’s claims asserting that Defendants acted unlawfully when they refused to release him from custody from April 28, 2021, until December 15, 2021. Id. However, because the undersigned did not address Plaintiff’s allegations

and arguments that, on later dates, Defendants acted unlawfully when they (1) revoked Plaintiff’s supervised release and (2) permitted his confinement on an “uncharged” crime, the District Court declined to dismiss with prejudice and, instead, exercised caution in allowing Plaintiff to clarify the nature of these claims by filing an amended complaint. Id. at 4–5. B. Amended Complaint Plaintiff filed his Amended Complaint on September 26, 2024. Dkt. 14. As before, Plaintiff alleges constitutional violations by the DOC, the ISRB, DOC and ISRB employees, Attorney General Ferguson, and Assistant Attorney General Dittman. Id. at 2–6. This time, Plaintiff organizes his claims into four Amended Counts for relief. Id. at 7–13. Each Amended Count concerns Plaintiff’s placement on supervised release in December 21, 2021, and the

eventual revocation of that release. For the first two Amended Counts, Plaintiff incorporates Counts I and II of his Initial Complaint by reference, stating “the word ‘vacate’ is replaced…with ‘invalid’ throughout. Everything else is the same.” Id. at 7–10. Incorporating Plaintiff’s requested substitution, the allegations in support of Amended Counts I and II are in pertinent part: Plaintiff’s Fourth Amendment rights were violated on March 23 and August 19, 2022,1 because warrants for his arrest obtained by community control officers were “predicated on a vacated invalid judgment

1 As indicated below, Amended Count III alleges false arrest/imprisonment arising out of arrests taking place on May 23 and August 19, 2022. While Amended Counts II and III may concern the same two arrests, the Court references all dates as they appear in the pleadings. and sentence.” Dkt. 1-1 at 7–8. On September 30, 2022, Plaintiff’s Fourth Amendment rights were again violated through revocation of his supervised release, reinstatement of his “vacated invalid judgment and sentence,” and the addition of a new “uncharged” crime of burglary. Id. Following these arrests, Plaintiff alleges his Fifth Amendment rights were violated because

“each defendant knew or should have known [his] Judgment and Sentence was vacated invalid.” Id. at 8. Finally, Plaintiff alleges that being forced to serve an “vacated invalid sentence” constitutes cruel and unusual punishment in violation of the Eighth Amendment. Id. at 9 (alleging that Defendants were given notice of his “vacated invalid” Judgment and Sentence and are therefore liable for permitting his allegedly unlawful imprisonment). In Amended Count III, Plaintiff alleges two claims of false arrest/imprisonment concerning his arrests by community control officers on May 23 and August 19, 2022. Id. at 10– 11. Plaintiff again asserts that the arrest warrants obtained by the community control officers were not supported by a valid judgment and sentence. Id. Additionally, Plaintiff alleges that his original state-court judgment did not impose a term of community control/supervision,2 making

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