Neaman v. Washington State Department of Corrections

District Court, W.D. Washington·Decided April 21, 2025·No. 3:24-cv-05176·Unknown

Opinion

UNITED STATES DISTRICT COURT AT TACOMA CHRISTOPHER NEAMAN, CASE NO. 3:24-CV-5176-BHS Plaintiff, ORDER v. DEPARTMENT OF CORRECTIONS; TERRA AMBROSE; ELISA SAHORE, Defendant.

This matter is before the Court on defendants Washington State Department of Corrections (DOC), Terra Ambrose, and Elisa Sahore’s motion for summary judgment. Dkt. 52. Neaman brings § 1983 claims against community custody officers Sahore and Ambrose and a false imprisonment claim against DOC for their acquiescence in the trial court’s modification of his sentence without jurisdiction. I. BACKGROUND On December 11, 2020, Neaman pled guilty in Pacific County superior court to possessing methamphetamine with intent to deliver, a felony. Dkt. 40-6. His offender score was 9+, resulting in a standard sentence range of 60 to 120 months. The court instead imposed 12 months of community custody under the Parenting Sentencing Alternative (PSA), RCW 9.94A.655, because Neaman was a single parent. One of the

conditions of his supervision was that he would not possess or consume controlled substances without a valid prescription. Id. His one-year supervision term was set to expire on December 11, 2021. Dkt. 40-7. In September and October 2021, Neaman consumed methamphetamine and heroin, violating the conditions of his supervision. The Department of Corrections (DOC) permitted Neaman to continue with his PSA. Dkt. 40-7 at 2.

On December 6, 2021, Neaman admitted to consuming methamphetamine again. Id. at 3. That same day, Ambrose emailed the prosecutor about Neaman’s violation, alerting him that Neaman’s sentence end date was “fastly approaching” on December 11. Dkt. 53-2 at 2; Dkt. 53-3 at 6. She submitted the new violation to the court a day later. Dkt. 40-7 at 2–4. The State signed a petition to revoke Neaman’s PSA sentence on

December 10, 2021, but the petition was not filed until December 14, 2021. Dkt. 40-8 at 2. Later in December—the record is unclear on exactly when—the State offered to extend Neaman’s community custody by six months instead. Dkt. 40-1 at 24–25, 30. On January 21, 2022, the court extended the PSA by six months. Dkt. 40-9 at 2. Neaman admits he was happy with that outcome because he “could still be a father.” Dkt.

40-1 at 30–31. On February 22, 2022, Neaman provided oral swab samples that tested positive for methamphetamine and heroin—his fourth violation. Dkt. 40-10 at 3. DOC recommended the court revoke Neaman’s PSA because he was “a high risk to the community, his 9-year old son, and himself.” Id. at 4. DOC conducted two more oral swab tests in March 2022, both of which tested positive for several controlled substances, including

methamphetamine and heroin. Dkts. 40-11, 40-12. On April 15, 2022, the court revoked Neaman’s PSA and ordered him detained. Dkt. 40-13. His defense counsel appealed the PSA revocation order to the state court of appeals, alleging procedural issues at the revocation hearing. Dkts. 40-16, 40-19. Neaman was assigned appellate counsel in September 2022, who “brought up the jurisdictional issue.” Dkt. 40-18.

On appeal, the State conceded that the trial court was not authorized to extend or subsequently revoke Neaman’s PSA sentence. State v. Neaman, 2023 WL 4195806, at *1 (Wash. Ct. App. 2023). The state court of appeals agreed, concluding that under the PSA statute, RCW 9.94A.655, “the trial court may only modify a PSA sentence during the community custody term.” Id. at *3. The court reversed Neaman’s revocation and

detention order. Id. Neaman sued his lawyers, David Arcuri and David Hatch, for legal malpractice, DOC for false imprisonment, and Ambrose and Sahore for § 1983 violations of his constitutional liberty interests. Dkt. 1-2. Arcuri and Hatch have since settled with Neaman.

DOC, Ambrose, and Sahore move for summary judgment. Dkt. 52. DOC argues Neaman’s false imprisonment claim fails because DOC’s conduct was pursuant to facially valid court orders. Id. at 7. Ambrose and Sahore claim immunity from suit. Id. at 10. 1

Neaman responds that DOC, Ambrose, and Sahore “participated in the pursuit of an invalid [court] order” that violated his constitutional rights. Dkt. 59 at 8. A. Summary Judgment Standard Summary judgment is proper if the pleadings, the discovery and disclosure materials on file, and any affidavits show that “there is no genuine dispute as to any

material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). In determining whether an issue of fact exists, the Court must view all evidence in the light most favorable to the nonmoving party and draw all reasonable inferences in that party’s favor. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248–50 (1986); Bagdadi v. Nazar, 84 F.3d 1194, 1197 (9th Cir. 1996). A genuine issue of material fact exists where

there is sufficient evidence for a reasonable factfinder to find for the nonmoving party. Anderson, 477 U.S. at 248. The inquiry is “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Id. at 251–52. The moving party bears the initial burden of showing that there is no evidence

which supports an element essential to the nonmovant’s claim. Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). Once the movant has met this burden, the nonmoving party 1 The parties do not address whether Neaman’s acceptance of the extended PSA was valid consent to the trial court’s jurisdiction over him. then must show that there is a genuine issue for trial. Anderson, 477 U.S. at 250. If the nonmoving party fails to establish the existence of a genuine issue of material fact, “the

moving party is entitled to judgment as a matter of law.” Celotex, 477 U.S. at 323–24. There is no requirement that the moving party negate elements of the non-movant’s case. Lujan v. Nat’l Wildlife Fed’n, 497 U.S. 871, 885 (1990). Once the moving party has met its burden, the non-movant must then produce concrete evidence, without merely relying on allegations in the pleadings, that there remain genuine factual issues. Anderson, 477 U.S. at 248.

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Neaman v. Washington State Department of Corrections, (W.D. Wash. 2025).

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