Oliver v. Holloway

CourtDistrict Court, M.D. Florida
DecidedAugust 11, 2025
Docket8:25-cv-01162
StatusUnknown

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

Bluebook
Oliver v. Holloway, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

RAYVORRIS OLIVER,

Plaintiff,

v. Case No. 8:25-cv-1162-TPB-NHA

ANTHONY HOLLOWAY, in his official capacity as Chief of Police of St. Petersburg Police Department,

Defendant. ______________________________________/

ORDER GRANTING IN PART DEFENDANT’S MOTION TO DISMISS

This matter is before the Court on “Defendant, Anthony Holloway, in his Official Capacity as Chief of Police of St. Petersburg Police Department’s, Dispositive Motion to Dismiss Counts of Plaintiff’s Complaint,” filed on May 13, 2025. (Doc. 5). Plaintiff Rayvorris Oliver filed a response in opposition on May 27, 2025. (Doc. 6). After reviewing the motion, response, court file, and the record, the Court finds as follows: Background1 On November 9, 2022, St. Petersburg Police Officer Reisz approached a vehicle taking part in a suspected narcotics transaction. But just as he approached

1 The Court accepts as true the facts alleged in the complaint for purposes of ruling on the pending motion to dismiss. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (“[W]hen ruling on a defendant’s motion to dismiss, a judge must accept as true all of the factual allegations contained in the complaint.”). The Court is not required to accept as true any legal conclusions couched as factual allegations. See Papasan v. Allain, 478 U.S. 265, 286 (1986). the vehicle to apprehend the unknown driver, the vehicle fled. Officer Reisz was wearing a body camera at the time of this encounter. Following the incident, Detective R. Long of the St. Petersburg Police identified Plaintiff Rayvorris Oliver as the unknown driver of the fleeing vehicle based on “prior involvements, suspect description, documented physical features,

and [the officer’s] investigation.” Plaintiff alleges that he was issued a traffic citation and subsequently arrested and charged with fleeing and eluding a law enforcement officer. According to Plaintiff, the underlying state court criminal proceedings took around nine months before the charge was ultimately dismissed after a state court judge “reviewed the video evidence in open court, and saw the obvious difference between the Plaintiff and the driver of the vehicle.” Plaintiff contends that the only

shared physical characteristics between himself and the individual on camera was that they were both black males. Plaintiff alleges that as a result of Defendant’s actions and omissions, he has suffered damages including “physical suffering, pain and suffering, physical inconvenience, physical discomfort, loss of time, mental anguish, embarrassment, humiliation, intentional infliction of emotional distress, disgrace and other emotional and reputational damages.” He also claims incurred

expenses, including past and future lost income and loss of job opportunities. On November 8, 2024, Plaintiff filed a lawsuit in the Sixth Judicial Circuit Court in and for Pinellas County, Florida, against Defendant in his official capacity. Plaintiff brings claims for a Fourth Amendment violation under 42 U.S.C. § 1983 (Count I), a Fourteenth Amendment violation under 42 U.S.C. § 1983 (Count II), a 42 U.S.C. § 1981 violation (Count III), false arrest and imprisonment under 42 U.S.C. § 1983 (Count IV), negligence (Count V), assault (Count VI), battery (Count VII), and invasion of privacy (Count VIII). Defendant timely removed the case to this Court on May 6, 2025. (Doc. 1). Legal Standard Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a

short and plain statement of the claim showing the [plaintiff] is entitled to relief.” Fed. R. Civ. P. 8(a). While Rule 8(a) does not demand “detailed factual allegations,” it does require “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). In order to survive a motion to dismiss, factual allegations must be sufficient “to state a claim to relief that is plausible on its face.” Id. at 570.

When deciding a Rule 12(b)(6) motion, review is generally limited to the four corners of the complaint. Rickman v. Precisionaire, Inc., 902 F. Supp. 232, 233 (M.D. Fla. 1995). Furthermore, when reviewing a complaint for facial sufficiency, a court “must accept [a] [p]laintiff’s well pleaded facts as true, and construe the [c]omplaint in the light most favorable to the [p]laintiff.” Id. (citing Scheuer v. Rhodes, 416 U.S. 232, 236 (1974)). “[A] motion to dismiss should concern only the

complaint’s legal sufficiency, and is not a procedure for resolving factual questions or addressing the merits of the case.” Am. Int’l Specialty Lines Ins. Co. v. Mosaic Fertilizer, LLC, 8:09-cv-1264-T-26TGW, 2009 WL 10671157, at *2 (M.D. Fla. 2009) (Lazzara, J.). Analysis In the motion to dismiss, Defendant argues that (1) Plaintiff fails to meet the requirements of Monell2 to assert liability against the City of St. Petersburg in Counts I through IV, and (2) Plaintiff failed to comply with the notice requirements as to his state law claims in Counts V through VIII.

Federal Claims (Counts I-IV) Defendant argues that Plaintiff fails to sufficiently state any federal claims in Counts I through IV. Specifically, Defendant contends that Plaintiff fails to allege sufficient prior incidents of a similar nature to demonstrate a policy or custom of the municipality. Plaintiff is required to do so as to his § 1983 claims and his purported § 1981 claim. See Christmas v. Harris Cnty., Ga., 51 F.4th 1348, 1355 (11th Cir. 2022); Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701, 735-36 (1989)

(explaining that similarly to § 1983 claims, “petitioner must show that the violation of his ‘right to make contracts’” protected by § 1981 “was caused by a custom or policy within the meaning of Monell and subsequent cases”). Under Monell, “[l]ocal governing bodies . . . can be sued directly under § 1983 for monetary, declaratory, or injunctive relief . . . pursuant to a governmental ‘custom’ even though such a custom has not received formal appeal

through the body’s official decisionmaking channels.” 436 U.S. 658, 690-91 (1978). Municipalities can only be held liable for “action pursuant to official municipal policy of some nature caused a constitutional tort;” a municipality cannot be liable under § 1983 on a respondeat superior theory simply because it employs a

2 Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978). tortfeasor. Id. at 691.

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Oliver v. Holloway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliver-v-holloway-flmd-2025.