Paul Buchanan v. Kootenai County; Kootenai County Sheriff’s Office; Kootenai County Correctional Facility; Correctional Health Partners, LLC; the city of Coeur D’Alene; Coeur D’Alene City Police Department; All in their individual and official capacity; Sheriff Robert Norris; Matt Sychla; Tim Clanin; Justin Bangs; Jared Reneau; J. Barber, Correctional Health Partners, LLC; Deputy R. Kinney; Deputy Smit; Deputy C. Shauer; Deputy Webb; Deputy Bonds; Deputy M. Cochran; Sgt. S. Ward; Sgt. R. Lafleur; Sgt. Ghan; Deputy Whipple; Sgt. B. Cox; Sgt. S. Malcom; Sgt N. Norris; Deputy J. Ekstrom; Sgt. Boots; Sgt. Peterson; Deputy Bolster; Deputy Maurer; Deputy Co

CourtDistrict Court, D. Idaho
DecidedFebruary 20, 2026
Docket2:23-cv-00097
StatusUnknown

This text of Paul Buchanan v. Kootenai County; Kootenai County Sheriff’s Office; Kootenai County Correctional Facility; Correctional Health Partners, LLC; the city of Coeur D’Alene; Coeur D’Alene City Police Department; All in their individual and official capacity; Sheriff Robert Norris; Matt Sychla; Tim Clanin; Justin Bangs; Jared Reneau; J. Barber, Correctional Health Partners, LLC; Deputy R. Kinney; Deputy Smit; Deputy C. Shauer; Deputy Webb; Deputy Bonds; Deputy M. Cochran; Sgt. S. Ward; Sgt. R. Lafleur; Sgt. Ghan; Deputy Whipple; Sgt. B. Cox; Sgt. S. Malcom; Sgt N. Norris; Deputy J. Ekstrom; Sgt. Boots; Sgt. Peterson; Deputy Bolster; Deputy Maurer; Deputy Co (Paul Buchanan v. Kootenai County; Kootenai County Sheriff’s Office; Kootenai County Correctional Facility; Correctional Health Partners, LLC; the city of Coeur D’Alene; Coeur D’Alene City Police Department; All in their individual and official capacity; Sheriff Robert Norris; Matt Sychla; Tim Clanin; Justin Bangs; Jared Reneau; J. Barber, Correctional Health Partners, LLC; Deputy R. Kinney; Deputy Smit; Deputy C. Shauer; Deputy Webb; Deputy Bonds; Deputy M. Cochran; Sgt. S. Ward; Sgt. R. Lafleur; Sgt. Ghan; Deputy Whipple; Sgt. B. Cox; Sgt. S. Malcom; Sgt N. Norris; Deputy J. Ekstrom; Sgt. Boots; Sgt. Peterson; Deputy Bolster; Deputy Maurer; Deputy Co) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Paul Buchanan v. Kootenai County; Kootenai County Sheriff’s Office; Kootenai County Correctional Facility; Correctional Health Partners, LLC; the city of Coeur D’Alene; Coeur D’Alene City Police Department; All in their individual and official capacity; Sheriff Robert Norris; Matt Sychla; Tim Clanin; Justin Bangs; Jared Reneau; J. Barber, Correctional Health Partners, LLC; Deputy R. Kinney; Deputy Smit; Deputy C. Shauer; Deputy Webb; Deputy Bonds; Deputy M. Cochran; Sgt. S. Ward; Sgt. R. Lafleur; Sgt. Ghan; Deputy Whipple; Sgt. B. Cox; Sgt. S. Malcom; Sgt N. Norris; Deputy J. Ekstrom; Sgt. Boots; Sgt. Peterson; Deputy Bolster; Deputy Maurer; Deputy Co, (D. Idaho 2026).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

PAUL BUCHANAN, Case No. 2:23-cv-00097-AKB Plaintiff, ORDER GRANTING MOTIONS v. TO DISMISS

KOOTENAI COUNTY; KOOTENAI COUNTY SHERIFF’S OFFICE; KOOTENAI COUNTY CORRECTIONAL FACILITY; CORRECTIONAL HEALTH PARTNERS, LLC; the city of COEUR D’ ALENE; COEUR D’ALENE CITY POLICE DEPARTMENT; All in their individual and official capacity; SHERIFF ROBERT NORRIS; MATT SYCHLA; TIM CLANIN; JUSTIN BANGS; JARED RENEAU; J. BARBER, CORRECTIONAL HEALTH PARTNERS, LLC; DEPUTY R. KINNEY; DEPUTY SMIT, DEPUTY C. SHAUER; DEPUTY WEBB; DEPUTY BONDS; DEPUTY M. COCHRAN, SGT. S. WARD; SGT. R. LAFLEUR; SGT. GHAN; DEPUTY WHIPPLE; SGT. B. COX; SGT. S. MALCOM; SGT N. NORRIS; DEPUTY J. EKSTROM; SGT. BOOTS; SGT. PETERSON; DEPUTY BOLSTER; DEPUTY MAURER; DEPUTY CONDON; DEPUTY SCHAUER; DEPUTY ALLEMAND; DEPUTY B. MORENO; DEPUTY COATES; DEPUTY J. ELLIOT; DEPUTY J. MAGANAS; DEPUTY C. LAW; MARIAH MEYER; JESSICA MELVIN; SARA MAURER; MONIQUE MINAS; JOHN BLANCHARD; JENNIFER MIX; JULIA SMITH; LORI WOODRUM; ELIZABETH GAYLE; MILISSA PRILLAMAN and JOHN AND JANE DOES I-XX,

Defendants. Pending before the Court is the Motion to Dismiss of Defendants John Blanchard, Lori Woodrum, Mariah Meyer, Monique Minas, Jennifer Mix, Sara Maurer, and Jessica Melvin; the Motion to Dismiss of Defendant Millissa Prillaman; and the Motion to Dismiss of Defendant Julia Smith (Dkts. 46, 56, 59). Having reviewed the record and the parties’ submissions, the Court finds

that the facts and legal argument are adequately presented, and that oral argument would not significantly aid its decision-making process, and it decides the motion on the parties’ briefing. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B); see also Fed. R. Civ. P. 78(b) (“By rule or order, the court may provide for submitting and determining motions on briefs, without oral hearings.”). For the reasons set forth below, the Court hereby grants all three motions to dismiss. I. BACKGROUND This 42 U.S.C. § 1983 action arises from Paul Buchanan’s arrest on March 25, 2021, and his subsequent detention at the Kootenai County Jail through April 1 (Dkt. 35 ¶¶ 137, 163, 184). On March 22, 2023, Paul Buchanan filed the Complaint against Defendants Kootenai County, Kootenai County Sheriff’s Office, and Kootenai County Correctional Facility (collectively

Kootenai); Correctional Health Partners, LLC (CHP); the City of Coeur d’Alene and Coeur d’Alene Police Department (collectively CDA); and numerous Kootenai County sheriff’s deputies (Dkt. 6). Additionally, Buchanan alleged that fictitiously named John and Jane Does I-XX “physical assessed [him] at least twice during his incarceration” and “either failed to properly monitor and assess [his] mental or physical health, or did monitor and assess [his] mental and physical health, but failed to provide him with proper treatment” (id. ¶¶ 74–75). CHP is the private entity which provided healthcare services at the jail at the time of Buchanan’s detention. Upon receipt of CHP’s initial disclosures and discovery responses, Buchanan learned the identity of the medical staff that CHP allegedly employed—namely Blanchard, Woodrum, Meyer, Minas, Mix, Maurer, Melvin, Prillaman, and Smith (collectively Defendants) (Dkt. 35 ¶¶ 103, 106, 109, 112, 115, 118, 121, 124, 127, 130; Dkt. 47 at 2–3). In December 2024, Buchanan moved for leave to amend his complaint to add new defendants (Dkt. 33). After no responses were filed in opposition, the Court granted Buchanan’s

motion, holding that the original Defendants’ nonresponse constituted consent to the motion (Dkt. 34 at 2). On January 14, 2025, Buchanan filed an amended complaint, alleging that, while detained, he received constitutionally inadequate medical care from Defendants (id. ¶¶ 210–17, 222, 230–34). Buchanan brought his claims against Defendants both in their individual and official capacities (Dkt. 35). Defendants moved to dismiss all claims brought against them under Rule 12(b)(6) of the Federal Rules of Civil Procedure, arguing that these claims fail to state viable claims because they are barred by the applicable statute of limitations (Dkt. 46-1 at 7).1 Further, Defendants move to dismiss the claims brought against them in their official capacities (id. at 11). II. ANALYSIS Defendants argue that the claims brought against them should be dismissed for two reasons:

First, Buchanan’s claims are barred by the applicable two-year statute of limitations and do not relate back to the original complaint (Dkt. 46-1 at 7). Second, as private individuals, Defendants cannot be sued in their official capacities as a matter of law (id. at 11). The Court addresses each argument in turn. A. Statute of Limitations and Relation Back Defendants argue that the claims brought against them should be dismissed because they are barred by the statute of limitations (Dkt. 46-1 at 7). A § 1983 claim is subject to dismissal

1 Because the arguments made between the three motions to dismiss overlap, the Court addresses the Rule 12(b)(6) motions collectively. under Rule 12(b)(6) if it is not brought within the applicable statute of limitations. Kimes v. Stone, 84 F.3d 1121, 1128–29 (9th Cir. 1996); see Jones v. Bock, 549 U.S. 199, 214–15 (2007). Section 1983, however, does not contain a statute of limitations. Flynt v. Shimazu, 940 F.3d 457, 461 (9th Cir. 2019). Rather, for purposes of § 1983 actions, federal courts borrow state statutes of

limitations for personal injury actions. Nance v. Ward, 597 U.S. 159, 174 (2022). In Idaho, personal injury actions have a two-year statute of limitations. Idaho Code § 5-219(4); see Gibson v. Ada Cnty., 133 P.3d 1211, 1219 (Idaho 2006). While state law governs the statute of limitations in § 1983 actions, federal law governs when the statute of limitations accrues. Wallace v. Kato, 549 U.S. 384, 388 (2007). A § 1983 claim “accrues when the plaintiff knows or has reason to know of the injury which is the basis of the action.” Morales v. City of Los Angeles, 214 F.3d 1151, 1153–54 (9th Cir. 2000). Thus, the Idaho statute of limitations runs for two years after the claim accrues under federal law. Here, Defendants argue Buchanan’s claims against the Defendants are barred by the applicable two-year statute of limitations (Dkt. 46-1 at 7). The parties do not appear to dispute that

the applicable two-year statute of limitations began to run on April 1, 2021—the date Buchanan was released from his detention (Dkt. 46-1 at 8; Dkt. 56-1 at 4; Dkt. 59-1 at 3). Based on this date, the latest statute of limitations period expired on April 1, 2023. While Buchanan’s original complaint was timely filed on March 22, 2023, the Defendants were not named until Buchanan filed his amended complaint on January 14, 2025—”nearly two years after the initial Complaint was filed and nearly four years after the underlying events giving rise to the claims” (Dkt. 46-1 at 9, 11). For this reason, Buchanan’s claims against Defendants are time-barred unless they relate back to his original complaint. 1.

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Paul Buchanan v. Kootenai County; Kootenai County Sheriff’s Office; Kootenai County Correctional Facility; Correctional Health Partners, LLC; the city of Coeur D’Alene; Coeur D’Alene City Police Department; All in their individual and official capacity; Sheriff Robert Norris; Matt Sychla; Tim Clanin; Justin Bangs; Jared Reneau; J. Barber, Correctional Health Partners, LLC; Deputy R. Kinney; Deputy Smit; Deputy C. Shauer; Deputy Webb; Deputy Bonds; Deputy M. Cochran; Sgt. S. Ward; Sgt. R. Lafleur; Sgt. Ghan; Deputy Whipple; Sgt. B. Cox; Sgt. S. Malcom; Sgt N. Norris; Deputy J. Ekstrom; Sgt. Boots; Sgt. Peterson; Deputy Bolster; Deputy Maurer; Deputy Co, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-buchanan-v-kootenai-county-kootenai-county-sheriffs-office-idd-2026.