Parker v. Great Falls Police Department

CourtDistrict Court, D. Montana
DecidedNovember 21, 2023
Docket4:23-cv-00056
StatusUnknown

This text of Parker v. Great Falls Police Department (Parker v. Great Falls Police Department) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parker v. Great Falls Police Department, (D. Mont. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION

JAMES H. PARKER, CV 23-56-GF-BMM

Plaintiff,

vs. ORDER

GREAT FALLS POLICE DEPARTMENT, CASCADE COUNTY SHERIFF’S OFFICE, STATE OF MONTANA,

Defendants. Plaintiff James H. Parker (“Parker”), a state prisoner proceeding without counsel, filed a proposed civil rights complaint pursuant to 42 U.S.C. § 1983 on September 19, 2023. (Doc. 2.) Parker’s filing is difficult to follow, and it is unclear exactly what claims he attempts to advance. It appears Parker may be alleging an injury to his ankle and/or a lack of medical care which occurred during his incarceration in Cascade County in either 2020 or 2021. (Id. at 5–7.) I. STATEMENT OF THE CASE A. Parties Parker does not name any individual actors as Defendants, but instead names the Great Falls Police Department, the Cascade County Sheriff’s Office, and the State of Montana. (Id. at 2–3.) 1 B. Allegations Parker states that he was arrested by the Great Falls Police Department at 1713 Valeria Way and placed in the “booking” section of the Cascade County Detention

Center. (Id. at 4.) Parker believes these events occurred in the summer of either 2020 or 2021. (Id. at 5.) Apparently, Parker had a cast on his right ankle at the time of his arrest and incarceration, and somehow one of the pins in his ankle was bent, resulting in further injury. (Id. at 5–6.) Parker was subsequently seen by medical staff at

Benefis Hospital. (Id. at 7.) Parker asks this Court to give him “due process” and whatever additional relief the Court sees fit. (Id. at 5.) II. INITIAL SCREENING Parker is proceeding pro se against a governmental defendant. Accordingly,

the Court must screen the Complaint before it is served to determine if it is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. §§ 1915A(b) and 1915(e)(2)(B).

A complaint is frivolous if it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams, 490 U.S. 319, 325 (1989). A complaint is malicious if not pleaded in good faith. Kinney v. Plymouth Rock Squab. Co., 236 U.S. 43, 46 (1915).

A complaint fails to state a claim upon which relief may be granted if a plaintiff fails to allege the “grounds” of his “entitlement to relief.” See Bell Atlantic Corp. v. 2 Twombly, 550 U.S. 544, 555 (2007) (internal brackets omitted). Rule 8(a)(2) of the Federal Rules of Civil Procedure requires a complaint to “contain sufficient factual

matter, accepted as true, to state a claim to relief that is plausible on its face.” Id. Rule 8 of the Federal Rules of Civil Procedure provides that a complaint “that states a claim for relief must contain . . . a short and plain statement of the claim

showing that the [plaintiff] is entitled to relief.” Fed. R. Civ. P. 8(a)(2). In order to satisfy the requirements in Rule 8, a complaint’s allegations must cross “the line from conceivable to plausible.” Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009). A two-step procedure determines whether a complaint’s allegations cross that

line. See Twombly, 550 U.S. at 556; Iqbal, 556 U.S. at 679. First, the Court must identify “the allegations in the complaint that are not entitled to the assumption of truth.” Iqbal, 556 U.S. at 679, 680. Factual allegations are not entitled to the

assumption of truth if they are “merely consistent with liability,” or “amount to nothing more than a ‘formulaic recitation of the elements’ of a constitutional” claim. Id. at 679, 681. A complaint stops short of the line between probability and the possibility of relief where the facts pled are merely consistent with a defendant’s

liability. Id. at 678. Second, the Court must determine whether the complaint states a “plausible” claim for relief. Iqbal, 556 U.S. at 679. A claim is “plausible” if the factual

allegations, which are accepted as true, “allow[ ] the court to draw the reasonable 3 inference that the defendant is liable for the misconduct alleged.” Id. at 678. This inquiry is “a context-specific task that requires the reviewing court to draw on its

judicial experience and common sense.” Id. at 679 (citation omitted). If the factual allegations, which are accepted as true, “do not permit the court to infer more than the mere possibility of misconduct, the complaint has alleged—but it has not

‘show[n]’— that the pleader is entitled to relief.” Id. (citing Fed. R. Civ. P. 8(a)(2)). “A document filed pro se is ‘to be liberally construed,’ and ‘a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.’” Erickson v. Pardu, 551 U.S. 89, 94 (2007);

cf. Fed. R. Civ. P. 8(e) (“Pleadings must be construed so as to do justice.”). III. ANALYSIS Parker’s current filing violates Rule 8 of the Federal Rules of Civil Procedure, as it fails to bring specific claims and factual allegations against each specific

defendant. These deficiencies might be cured by a clearer statement of the claims, facts to support those claims, and a clearer statement of defendants’ actions. Parker will be given an opportunity to file an amended complaint, but he must meet the following legal standards.

A. Excessive Force Claim Although Parker references no federal constitutional provisions or law, it appears he may be attempting to raise a claim under the Fourth Amendment of the 4 United States Constitution. Though the Court is not certain, it seems that Parker may believe an unidentified individual used excessive force during his arrest and

transport to the detention center that resulted in injury to his ankle. In general, a seizure of a person is unreasonable under the Fourth Amendment if a police officer uses excessive force in making a lawful arrest. The Fourth

Amendment’s “objective reasonableness” standard “governs a free citizen’s claim that law enforcement officials used excessive force,” in any search or seizure. See Graham v. Connor, 490 U.S. 386, 388 (1989). For an excessive use of force claim, a plaintiff must plausibly plead that the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kinney v. Plymouth Rock Squab Co.
236 U.S. 43 (Supreme Court, 1915)
Edelman v. Jordan
415 U.S. 651 (Supreme Court, 1974)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Idaho v. Coeur D'Alene Tribe of Idaho
521 U.S. 261 (Supreme Court, 1997)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Noll v. Carlson
809 F.2d 1446 (Ninth Circuit, 1987)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
Parker v. Great Falls Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-great-falls-police-department-mtd-2023.