Monroe v. Leopold

CourtDistrict Court, S.D. Illinois
DecidedAugust 28, 2020
Docket3:20-cv-00731
StatusUnknown

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

Bluebook
Monroe v. Leopold, (S.D. Ill. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

JAMES L. MONROE and ) JENNIFER A. MONROE, ) ) Plaintiffs, ) ) Case No. 3:20-CV-731-MAB vs. ) ) MARK LEOPOLD and ) STEVE JOHNSON, ) ) Defendants. )

MEMORANDUM AND ORDER

BEATTY, Magistrate Judge: This matter is currently before the Court on Plaintiffs James and Jennifer Monroe’s motions for leave to proceed in forma pauperis (“IFP”) (Doc. 3, Doc. 4), their motion for recruitment of counsel (Doc. 5), and for a preliminary review of the complaint in accordance with 28 U.S.C. § 1915(e)(2). The motion to dismiss filed by Defendants Mark Leopold and Steve Johnson (Doc. 9) is also before the Court. 1. Motions to Proceed IFP A federal court is authorized under 28 U.S.C. § 1915(a)(1) to permit an indigent party to proceed in a civil action without prepaying the filing fee if the party “submits an affidavit that includes a statement of all assets [he] possesses [showing] that the person is unable to pay such fees or give security therefor.” The IFP motions submitted by the Monroes indicate that they are not employed. They have no income. The only money they’ve received in the last twelve months is “$50 daily for motel fee.” They have no money in a bank account. The only property they own is a sixteen-year-old car that is currently impounded. Based upon the foregoing

information, the Court finds the Monroes are indigent within the meaning of § 1915(a)(1) and unable to pay the filing fee. Accordingly, their IFP motions are granted. 2. Preliminary Review of the Complaint Because the Monroes are permitted to proceed IFP, the Court must review the complaint and dismiss any portion of it that fails to state a claim upon which relief can be granted. 28 U.S.C. § 1915(e)(2); Rowe v. Shake, 196 F.3d 778, 783 (7th Cir. 1999)

(“[D]istrict courts have the power to screen complaints filed by all litigants, prisoners and non-prisoners alike, regardless of fee status.”). An action fails to state a claim upon which relief can be granted if it does not plead “sufficient factual matter . . . to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). At this juncture, all well-pleaded

allegations are accepted as true and viewed in the light most favorable to the plaintiff. Arnett v. Webster, 658 F.3d 742, 751 (7th Cir. 2011). Pro se complaints have the additional benefit of being construed liberally and held to a less stringent standard than pleadings drafted by a lawyer. Id. Here, the complaint alleges that the Monroe’s car was impounded on October 19,

2019, and then illegally searched by a drug dog (Doc. 2, p. 5). The car was impounded again on December 9, 2019, despite being legally parked at a hospital (Id.). The car was impounded a third time in March 2020, while it was parked overnight at a local church (Id.). The car was impounded a fourth time in June 20, 2020 (Id.), and remained there as of July 15, 2020 (Doc. 3, p. 3). The Monroes claim the repeated impoundment of their car and unspecified

belittling constitutes harassment (Doc. 2, p. 5). They allege they are being harassed “because of our last name [and] past drugs” and discriminated against because they are poor, unemployed, and homeless and living in their car (Id.). They request damages in the amount of $7,000 (Id. at p. 6). The Court begins by discussing the capacity in which the Monroes are suing Mark Leopold, the Mayor of Swansea, Illinois, and Steve Johnson, the Chief of Police in

Swansea. A § 1983 suit can be brought against a defendant in his official capacity or in his individual capacity. Hill v. Shelander, 924 F.2d 1370, 1372 (7th Cir. 1991). An individual-capacity claim seeks to impose personal liability upon a defendant for his own tortious actions that were committed under color of state law. Id.; Miller v. Smith, 220 F.3d 491, 494 (7th Cir. 2000). An official-capacity claim, on the other hand, seeks to impose

liability on a defendant as a “party to the execution or implementation of official policy or conduct by a government . . . .” Hill, 924 F.2d at 1372. Official-capacity suits “generally represent only another way of pleading an action against an entity of which an officer is an agent.” Id. Here, the complaint indicates that the Monroes seek to impose liability on Mayor

Leopold and Chief Johnson because “[t]he policy or custom of this official’s government agency violate[d] my rights” (Doc. 2), which leads the Court to believe the Monroes are attempting to allege an official-capacity claim against Mayor Leopold and Chief Johnson. In order to state an official-capacity claim under § 1983, the complaint must allege that an official policy, custom, or practice “not only caused the constitutional violation, but was the ‘moving force’ behind it.” Estate of Sims ex rel. Sims v. Cty. of Bureau, 506 F.3d 509, 514

(7th Cir. 2007). See also Monell v. Department of Soc. Servs., 436 U.S. 658, 694 (1978). A plaintiff may demonstrate an official policy through: (1) an express policy that causes a constitutional deprivation when enforced; (2) a widespread practice that is so permanent and well-settled that it constitutes a custom or practice; or (3) an allegation that the constitutional injury was caused by a person with final policymaking authority. Sims, 506 F.3d at 515.

There are no allegations in the complaint, nor can it be inferred, that the impoundments and purported harassment occurred pursuant to any express policy or widespread practice (see Doc. 2). Similarly, there are no allegations that the impoundments and purported harassment was done by an official with final policymaking authority. Even if the Court assumed that Mayor Leopold and/or Chief

Johnson had such authority, the complaint does not allege that they took the allegedly unconstitutional actions against the Monroes. Consequently, the complaint fails to state a claim against the Defendants in their official capacities. Additionally, a claim against the Defendants in their individual capacities is not plausible based on the facts alleged in the complaint. The complaint does not include any

allegations that Mayor Leopold and Chief Johnson personally and directly participated in the alleged impoundments or any other unconstitutional conduct (see Doc. 2). Estate of Perry v. Wenzel, 872 F.3d 439, 459 (7th Cir. 2017) (“Individual liability pursuant to § 1983 ‘requires personal involvement in the alleged constitutional deprivation.’”) (citation omitted). The complaint also does not include any allegations that Mayor Leopold or Chief Johnson knew about the alleged harassment and discrimination and

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