Moore v. Union County Mississippi

CourtDistrict Court, N.D. Mississippi
DecidedFebruary 17, 2023
Docket3:22-cv-00092
StatusUnknown

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

Bluebook
Moore v. Union County Mississippi, (N.D. Miss. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI OXFORD DIVISION RICHARD MOORE PLAINTIFF V. NO: 3:22CV92-GHD-JMV UNION COUNTY, MISSISSIPPI, et al. DEFENDANTS

MEMORANDUM OPINION This matter is before the Court on Defendant Union County, Mississippi, and Defendant Sheriff Jimmy Edwards’ Motion for Judgment on the Pleadings. [14]. Plaintiff has not responded in opposition to the present motion, and upon due consideration of the motion and applicable authority, the Court is prepared to rule. Factual Background Plaintiff Richard Moore, who is proceeding pro se, brings this lawsuit against Union County, Mississippi, Sheriff Jimmy Edwards, Lee County, Mississippi, Sheriff Jim. H. Johnson, and Deputy Bobby Bean. Plaintiff asserts that he was subjected to violations of his constitutional rights on and around May 4, 2022, when Union County Sheriff's Deputies arrested him on his property for Felony Malicious Mischief and searched and seized his vehicle. According to Moore, he was not presented with copies of the arrest and search warrant until after his release from jail. Further, Moore claims that the warrants were dated May 5, 2022. While in Lee County jail after the May 4, 2022, arrest, Moore claims he was denied medication and denied a phone call with his family and attorney. Moore further claims that he was threatened by “jailers” with a taser if he refused to stop complaining of chest pains. While meeting with a nurse in the Lee County Jail, Moore alleges that he was told he was in good health, which Moore contends was a lie. Moore states in the complaint that he was then transported to

Chickasaw County Jail where he suffered from a stroke, requiring treatment at Calhoun Baptist Hospital and later at Southaven Baptist Hospital. On May 25, 2022, Moore filed this lawsuit and Defendants Union County, Mississippi and Sheriff Jimmy Edwards seek judgment on the pleadings. Standard of Review After the pleadings are closed—but early enough not to delay trial—a party may move for judgment on the pleadings.” Fed. R. Civ. P. 12(c). A Rule 12(c) motion is governed by the same standards as a Rule 12(b)(6) motion. See Brown v. CitiMortgage, Inc., 472 Fed. App’x. 302, 303 (Sth Cir. 2012) (citing St. Paul Mercury Ins. Co. v. Williamson, 224 F.3d 425, 440 n.8 (5th Cir. 2000)). “A motion brought pursuant to [Rule] 12(c) is designed to dispose of cases where the material facts are not in dispute and a judgment on the merits can be rendered by looking to the substance of the pleadings and any judicially noticed facts.” Hebert Abstract Co. v. Touchstone Props., Ltd., 914 F.2d 74, 76 (Sth Cir. 1990) (citing SA Charles A. Wright & Arthur R. Miller, Federal Practice and Procedure § 1367, at 509-10 (1990)). When deciding a Rule 12(b)(6) motion to dismiss, the Court is limited to the allegations set forth in the complaint and any documents attached to the complaint. Walker v. Webco Indus., Inc., 562 F. App’x 215, 216-17 (Sth Cir. 2014) (citing Kennedy v. Chase Manhattan Bank USA, NA, 369 F.3d 833, 839 (Sth Cir. 2004)). “[A plaintiff's] complaint therefore ‘must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” Phillips v. City of Dallas, Tex., 781 F.3d 772, 775—76 (Sth Cir. 2015) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009)). A claim is facially plausible when the pleaded factual content “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Jgbal, 556 U.S. at

678, 129 S. Ct. 1937 (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007)). “[P]laintiffs must allege facts that support the elements of the cause of action in order to make out a valid claim.” Webb v. Morella, 522 F. App’x 238, 241 (5th Cir. 2013) (quoting City of Clinton, Ark. v. Pilgrim’s Pride Corp., 632 F.3d 148, 152-53 (5th Cir. 2010) (internal quotation marks omitted)). “[C]onclusory allegations or legal conclusions masquerading as factual conclusions will not suffice to prevent a motion to dismiss.” /d. (quoting Fernandez— Montes v. Allied Pilots Ass'n, 987 F.2d 278, 284 (5th Cir. 1993) (internal quotation marks omitted)). “Dismissal is appropriate when the plaintiff has not alleged ‘enough facts to state a claim to relief that is plausible on its face’ and has failed to ‘raise a right to relief above the speculative level.’” Emesowum v. Hous. Police Dep’t, 561 F. App’x 372, 372 (5th Cir. 2014) (quoting Twombly, 550 U.S. at 555, 570, 127 8. Ct. 1955). Analysis Moore contends that his Fifth and Fourteenth Amendment rights were violated “by denial of his Due Process of his liberty and property.” [1]. Concerning the Defendants who brought the present motion, Moore appears to contend that he was wrongfully arrested and that his vehicle was wrongfully searched. Moore’s claim for denial of due process under the Fifth Amendment fails as an initial matter because the Defendants are state actors, not federal actors. Jones y. City of Jackson, 203 F.3d 875, 880 (5" Cir. 2000). Moore has not alleged that Union County, Mississippi, and Sheriff Jimmy Edwards were acting under authority of the federal government. Also, “where a claim of unlawful detention was accompanied by allegations that the initial arrest was not supported by valid probable cause” analysis is proper under the Fourth Amendment, not the Fourteenth Amendment. Jauch v. Choctaw County, 874 F.3d 425, 429 (5" Cir. 2017). Even though Moore

did not outright allege his claims under the Fourth Amendment, the Court will consider Moore’s allegations in the context of the Fourth Amendment. The Court will first address Moore’s claims as to Sheriff Edwards. As the Defendants acknowledge in the present motion, Moore only refers to Sheriff Edwards in the complaint when listing the names of the defendants; Sheriff Edwards is not mentioned directly in any substantive allegation in the complaint. “[A] plaintiff bringing a section 1983 action must specify the personal involvement of each defendant[.]” Murphy v. Kellar, 950 F.2d 290, 292 (5th Cir. 1992). Moore fails to demonstrate how Sheriff Edwards is personally involved in the alleged wrongful arrest and search. However, Plaintiff Moore does, however, refer to Union County Sheriff's officers and officials in the complaint when describing who searched his property and arrested him. Even when giving Moore the leniency awarded to pro se plaintiffs and assuming that Sheriff Edwards is in this group of officers and officials referred to by Moore, the Plaintiff’s claims still fail.

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Bluebook (online)
Moore v. Union County Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moore-v-union-county-mississippi-msnd-2023.