Moss v. Booth

CourtDistrict Court, W.D. Virginia
DecidedSeptember 5, 2024
Docket7:23-cv-00112
StatusUnknown

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

Bluebook
Moss v. Booth, (W.D. Va. 2024).

Opinion

CLERK'S OFFICE U.S. DIST. CO AT ROANOKE, VA FILED IN THE UNITED STATES DISTRICT COURT September 05, 2024 FOR THE WESTERN DISTRICT OF VIRGINIA {UR A AUSTIN, CLERK ROANOKE DIVISION s/A. Beeson DEPUTY CLERK KEITH EDWARD MOSS, ) Plaintiff, ) Case No. 7:23-cv-00112 ) Vv. ) ) By: Michael F. Urbanski STEPHANIE REED, et al., ) Senior United States District Judge Defendants. ) MEMORANDUM OPINION Keith Edward Moss, a Virginia inmate proceeding pro se, filed this civil rights action under 42 U.S.C. § 1983 against Lynchburg Mayor Stephanie Reed, former Mayor Mary Jane Dolan, Lynchburg Police Chief Ryan Zuidema, twelve officers with the Lynchburg Police Department (LPD), and eight employees of the Blue Ridge Regional Jail Authority (BRRJA). The case is one of several suits that Moss filed against municipal and correctional officials in 2023, and it includes some of the same claims asserted in Moss v. Trent, 7:23-cv-00110 (W.D. Va.), which remains pending. Having reviewed the complaint, the court concludes that the claims against Reed, Dolan, Zuidema, and the BRRJA officials must be dismissed pursuant to 28 U.S.C. § 1915A(b)(1). The case will proceed on Moss’s claims against the twelve LPD officers named as defendants. I. Background According to the complaint, which spans more than 100 pages, Moss was arrested by LPD Officers J.B. Cox and C.N. Harris on February 13, 2021. Compl. 15, ECF No. 1. He claims that the initial seizure and search of his person violated the Fourth Amendment and that he was subjected to excessive force in the course of the arrest. See id. at 15-23, 34-35,

89. At some point, LPD Officers C.D. Pritchard Williams, J. Massie, C.M. Booth, W.M. Witcher, M. Donnellan, B. Gibson, B. Ashley, J. Payne, and Rippy arrived on the scene, along with an unknown officer identified as “Unknown LPD Reporting Officer of Police Report

CC #2021-002204.” Id. at 39, 102. Moss claims that the police officers either used excessive force against him or failed to intervene in the use of excessive force. Id. at 39, 102. For instance, Moss alleges that some of the officers used their hands and feet to twist and stand on the chain connected to his leg shackles, while others failed to protect him from being harmed. Id. at 39. He further alleges that one of the officers slammed his head on the ground and that several of the officers punched him in the face after he was placed in a patrol car. Id.

at 39–40. Following his arrest, Moss was taken to the Lynchburg Adult Detention Center (LADC), a correctional facility operated by the BRRJA. He alleges that LADC Officer J. Clark conducted a “disgraceful strip search” after he arrived there, during which Clark spread open his buttocks to observe his anal cavity. Id. at 25–26. Moss claims that the search violated his rights under the Fourth Amendment. Id. at 27, 94. Moss also claims that he was “severely

injured” when he arrived at the detention center and that LADC Officers J. Clark, J.A. Miller, B. Barker, and J. Hamlett acted with deliberate indifference to his serious medical needs. Id. at 69–71, 103. Moss alleges that Mayor Reed is “legally responsible for the overall operation of the City of Lynchburg and each department under the City of Lynchburg’s jurisdiction, including the Lynchburg Police Department,” and that former Mayor Dolan had the same

responsibilities at the time of the “police-citizen encounter” on February 13, 2021. Id. at 11. Moss further alleges that he “wrote a personal letter” to Dolan regarding the events giving rise to this action and that he did not receive a response. Id. at 66. He asserts that Dolan “failed to properly oversee and/or reasonably respond to the unlawful conduct of the [LPD].” Id.

Similarly, Moss asserts that LPD Chief Zuidema “failed to properly oversee and/or correct the misconduct of law enforcement officers assigned to the [LPD]” and that BRRJA Administrators Trent, Salmon, Moore, and Enochs “fail[ed] to properly oversee and reasonably respond to the misconduct of the officers assigned to the [LADC].” Id. at 68, 104. Based on these assertions, Moss claims that the supervisory officials violated his constitutional rights. Id. at 104.

II. Standards of Review The court is required to review a complaint in a civil action in which an inmate seeks redress from a governmental entity or an officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The court must “dismiss the complaint, or any portion of the complaint, if the complaint . . . is frivolous [or] malicious.” 28 U.S.C. § 1915A(b)(1). “Because district courts are not required to entertain duplicative or redundant lawsuits, they may dismiss them as

frivolous or malicious” pursuant to this provision. McClary v. Lightsey, 673 F. App’x 357, 357 (4th Cir. 2017) (citing Aziz v. Burrows, 976 F.2d 1158, 1158 (8th Cir. 1992)). “Generally, lawsuits are duplicative if the parties, issues, and available relief are not different from each other.” Id. The court must also “dismiss the complaint, or any portion of the complaint, if the complaint . . . fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(1).

To survive dismissal for failure to state a claim, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court

to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. III. Discussion A. Claims Against Clark, Miller, Barker, Hamlett, Trent, Salmon, and Enochs Having reviewed the complaint, the court concludes that the claims against defendants Clark, Miller, Barker, Hamlett, Trent, Salmon, and Enochs must be dismissed as duplicative. One form of duplicative litigation involves what is referred to as “claim splitting.” Sensormatic

Sec. Corp. v. Sensormatic Elecs. Corp., 273 F. App’x 256, 265 (4th Cir. 2008). “The rule against claim splitting prohibits a plaintiff from prosecuting its case piecemeal and requires that all claims arising out of a single wrong be presented in one action.” Id. Pursuant to this rule, a second claim is barred “if the claim involves the same parties and arises out of the same transaction or series of transactions as the first claim.” Id. (internal quotation marks omitted). “When one suit is pending in federal court, a plaintiff has no right to assert another action on

the same subject in the same court, against the same defendant at the same time.” Id. (internal quotation marks omitted). As summarized above, Moss claims that he was unlawfully strip-searched by Clark upon entering the LADC on February 13, 2021. He also claims that he was severely injured when he arrived at the detention center and that Clark, Miller, Barker, and Hamlett acted with deliberate indifference to his serious medical needs. The complaint filed in Moss v. Trent, No.

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Moss v. Booth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moss-v-booth-vawd-2024.