Naji v. City of Augusta

CourtDistrict Court, S.D. Georgia
DecidedOctober 19, 2023
Docket1:23-cv-00132
StatusUnknown

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

Bluebook
Naji v. City of Augusta, (S.D. Ga. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF GEORGIA

AUGUSTA DIVISION

ISSAC ALI NAJI, ) ) Plaintiff, ) ) v. ) CV 123-132 ) CITY OF AUGUSTA; RICHMOND ) COUNTY SHERIFF’S OFFICE; OFFICER ) HOOD; OFFICER MITCHELL; ) SERGEANT ROBERTSON; and ) SERGEANT ROBERTS, ) ) Defendants. ) _________

O R D E R _________

Plaintiff, currently detained at the Charles B. Webster Detention Center (“the Jail”) in Augusta, Georgia, is proceeding pro se and in forma pauperis (“IFP”) in this case filed pursuant to 42 U.S.C. § 1983. Because he is proceeding IFP, Plaintiff’s complaint must be screened to protect potential defendants. Phillips v. Mashburn, 746 F.2d 782, 785 (11th Cir. 1984) (per curiam); Al-Amin v. Donald, 165 F. App’x 733, 736 (11th Cir. 2006) (per curiam). I. Screening the Complaint Plaintiff names the following Defendants: (1) City of Augusta; (2) Richmond County Sheriff’s Office; (3) Officer Hood; (4) Officer Mitchell; and (5) Sergeant Roberts.1 (See doc.

1When opening the case, the Clerk of Court separately listed “Sergeant Robertson” and “Sergeant Roberts” as Defendants. However, as is clear from the statement of claim and as described herein, there is only one “Sergeant Roberts” against whom Plaintiff raises claims. no. 1, pp. 1-3, 5.) He sues Defendants in their individual and official capacities. (Id. at 2-3, 6.) Taking all of Plaintiff’s factual allegations as true, as the Court must for purposes of the present screening, the facts are as follows. On September 15, 2021, Defendant Hood escorted Plaintiff, a pretrial detainee at the Jail,2 to the medical department to have staples removed from a prior injury. (Id. at 4.) During the course of the medical visit, Plaintiff asked to stop the treatment and return to his

cell. (Id. at 5.) On the way back to Plaintiff’s cell, Defendant Hood wrestled Plaintiff to the ground, hit Plaintiff’s head on the ground and wall several times while he was handcuffed, and choked Plaintiff until he was nearly unconscious. (Id.) Defendant Hood “proceeded to throw Plaintiff into a restraint chai[r] and left the Plaintiff there for several hours with no food or water and soiled in urine and feces.” (Id.) Defendants Roberts and Mitchell watched Defendant Hood’s mistreatment of Plaintiff but failed to intervene to stop him. (Id. at 6.) Plaintiff seeks an unspecified amount damages against all Defendants, as well as a declaration that his constitutional rights have been violated. (Id.) Plaintiff also wants Defendants Hood, Roberts, and Mitchell to lose their jobs. (Id.)

2Plaintiff asserts he is both a pretrial detainee and a convicted and sentenced state prisoner. (Doc. no. 1, p. 4.) However, for the purpose of screening the complaint, the Court presumes he was a pretrial detainee at the time of the alleged events – September 15, 2021 – because his list of open criminal cases in Richmond County start in 2022. See Richmond Cnty. Clerk of Court Web Docket, available at https://cocaugustaga.com/mainpage.aspx (follow “Criminal Search” hyperlink; then search for “Naji, Issac Ali,” 2022RCCR00030, last visited Oct. 19, 2023); see also United States v. Jones, 29 F.3d 1549, 1553 (11th Cir. 1994) (noting court may take judicial notice of another court’s records to establish existence of ongoing litigation and related filings). 2 Liberally construing Plaintiff’s allegations in his favor and granting him the benefit of all reasonable inferences to be derived from the facts alleged, the Court finds Plaintiff has arguably states a viable excessive force claim against Defendant Hood. See Robinson v. Lambert, 753 F. App’x 777, 780 (11th Cir. 2018) (per curiam) (“For an excessive force claim, a pretrial detainee must show that the force used against him was objectively unreasonable.” (citing Kingsley v.

Hendrickson, 576 U.S. 389, 396-97 (2015)). The Court also finds Plaintiff arguably states a viable claim against Defendants Roberts and Mitchell for failing to intervene when they witnessed Defendant Hood’s use of force against Plaintiff. See Salvato v. Miley, 790 F.3d 1286, 1295 (11th Cir. 2015) (“An officer who is present at the scene and fails to take reasonable steps to protect the victim of another officer’s use of excessive force can be held liable for his nonfeasance.” (alterations and citations omitted)). Finally, the Court finds Plaintiff arguably states a viable conditions of confinement claim against Defendants Hood, Roberts, and Mitchell

based on the allegations of the denial of food, water, and a bathroom for several hours after Defendant Hood’s use of force. Grochowski v. Clayton Cnty., 961 F.3d 1311, 1318 (11th Cir. 2020). In a companion Report and Recommendation, the Court recommends dismissal of “Sergeant Robertson,” the City of Augusta, and Richmond County Sheriff’s Office, as well as any official capacity claims for monetary damages. II. Instructions

IT IS HEREBY ORDERED service of process shall be effected on Defendants Hood, Roberts, and Mitchell. The United States Marshal shall mail a copy of the complaint, (doc. no. 1), and this Order by first-class mail and request that each Defendant waive formal service of the

3 summons. Fed. R. Civ. P. 4(d). Individual defendants have a duty to avoid unnecessary costs of serving the summons, and if a defendant fails to comply with the request for waiver, the defendant must bear the costs of personal service unless good cause can be shown for failure to return the waiver. Fed. R. Civ. P. 4(d)(2). A defendant whose return of the waiver is timely does not have to answer the amended complaint until sixty days after the date the Marshal mails the

request for waiver. Fed. R. Civ. P. 4(d)(3). However, service must be effected within ninety days of the date of this Order, and the failure to do so may result in the dismissal of any unserved defendant or the entire case. Fed. R. Civ. P. 4(m). Plaintiff is responsible for providing sufficient information for the Marshal to identify and locate each Defendant to effect service. IT IS FURTHER ORDERED Plaintiff shall serve upon the defendants, or upon their defense attorney(s) if appearance has been entered by counsel, a copy of every further pleading or other document submitted to the Court. Plaintiff shall include with the papers to be filed a

certificate stating the date a true and correct copy of any document was mailed to the defendant or their counsel. Fed. R. Civ. P. 5; Loc. R. 5.1. Every pleading shall contain a caption setting forth the name of the court, the title of the action, and the file number. Fed. R. Civ. P. 10(a). Any paper received by a District Judge or Magistrate Judge that has not been properly filed with the Clerk of Court or that fails to include a caption or certificate of service will be returned.

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Related

Jamil A. Al-Amin v. James E. Donald
165 F. App'x 733 (Eleventh Circuit, 2006)
Phillips v. Mashburn
746 F.2d 782 (Eleventh Circuit, 1984)
United States v. Marvin P. Jones
29 F.3d 1549 (Eleventh Circuit, 1994)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Salvato Ex Rel. Estate of Salvato v. Miley
790 F.3d 1286 (Eleventh Circuit, 2015)
Donald Grochowski v. Clayton County, Georgia
961 F.3d 1311 (Eleventh Circuit, 2020)

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Naji v. City of Augusta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/naji-v-city-of-augusta-gasd-2023.