Pinyan v. City of Oneonta, Alabama

CourtDistrict Court, N.D. Alabama
DecidedJuly 16, 2025
Docket2:25-cv-00483
StatusUnknown

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

Bluebook
Pinyan v. City of Oneonta, Alabama, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

RYAN PINYAN, } } Plaintiff, } } v. } Case No.: 2:25-cv-00483-RDP } CITY OF ONEONTA, ALABAMA, et al., } } Defendants. }

MEMORANDUM OPINION AND ORDER

This case is before the court on the motions to dismiss filed by Defendants Charles Clifton (Doc. # 4) and City of Oneonta, Alabama (Doc. # 6). These motions have been fully briefed (Docs. # 5, 13, 15; 7, 12, 16) and are ripe for decision. Because Plaintiff’s complaint is a shotgun pleading, the court will strike Plaintiff’s complaint and order him to file an amended complaint. Accordingly, the motions to dismiss (Docs. # 4, 6) are due to be denied without prejudice. I. Background This is a case about the termination of a former police officer who worked for the City of Oneonta. (Doc. 1-1 ¶¶ 10-12). Plaintiff Ryan Pinyan (“Plaintiff”) alleges that his termination was wrongful because it was done without a pretermination hearing. (Id. ¶¶ 10, 13). Accordingly, Plaintiff has asserted claims contained in a single count alleging violations of his federal and state procedural due process rights and violation of Alabama Code § 11-43-230(a). Plaintiff’s complaint alleges the following. He was employed with the City of Oneonta (Doc. # 1-1 ¶ 6). During his employment, Plaintiff was a Patrolman for several years and later became a K-9 officer. (Id. at 15). On or about November 20, 2023, while attempting to make an arrest, Plaintiff was shot in the right leg. (Id. ¶ 7). After being medically treated, Plaintiff began receiving workers compensation. (Id.). On May 6, 2024, Plaintiff was traveling to be a witness before a grand jury and Defendant Charles Clifton (“Clifton”) stopped him to demand that he sign workers compensation checks. (Id. ¶ 8). Clifton asked a corporal to read Plaintiff his “Garrity” rights and required Plaintiff to sign a form acknowledging this. (Id. ¶ 9). Clifton then asked Plaintiff a series of questions about his relationship with various single and married women. (Id.).

On May 10, 2024, Clifton, through “Corporal Harris and Lt. David Egan,” terminated Plaintiff and ordered him to surrender his weapon. (Id. ¶ 11). This termination happened without Plaintiff being afforded a pretermination hearing, notice of any charges against him, or an opportunity to have his counsel present. (Id. ¶ 10). Plaintiff claims he was deprived of “his job, his automobile, and his weapon.” (Id. ¶ 12). Additionally, although Plaintiff was allowed to keep his K-9 dog, he was not allowed to receive the more than $10,000 that he had raised for medical treatment of the K-9 dog. (Id. ¶ 15). Plaintiff asserts a single count against both Defendants: “Plaintiff was in effect terminated for no valid legal reason.” (Id. ¶¶ 16-17). In this count, Plaintiff asserts a violation of Alabama

Code § 11-43-230(a), a procedural due process violation, an unspecified “violation of the City of Oneonta policies,” and a violation of Article I, Section 13 of the Alabama Constitution. (Id.). Plaintiff also contends that he has suffered “mental anguish, financial, and emotional harm as a direct result of the actions of the Defendants.” (Id. ¶ 17(e)). Additionally, Plaintiff’s prayer for relief appears to state a claim for conspiracy. (Id. at 20). II. Standard of Review The Federal Rules of Civil Procedure also require that a complaint provide “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). However, the complaint must include enough facts “to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). Pleadings that contain nothing more than “a formulaic recitation of the elements of a cause of action” do not satisfy Rule 8, nor do pleadings suffice that are based merely upon “labels and conclusions” or “naked assertion[s]” without supporting factual allegations. Id. at 555, 557. To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a complaint

must “state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Although “[t]he plausibility standard is not akin to a ‘probability requirement,’” the complaint must demonstrate “more than a sheer possibility that a defendant has acted unlawfully.” Id. A plausible claim for relief requires a plaintiff to allege “enough fact[s] to raise a reasonable expectation that discovery will reveal evidence” to support the claim. Twombly, 550 U.S. at 556. In deciding a Rule 12(b)(6) motion to dismiss, courts view the allegations in the complaint

in the light most favorable to the non-moving party. Watts v. Fla. Int’l Univ., 495 F.3d 1289, 1295 (11th Cir. 2007). In addition, “a court should 1) eliminate any allegations in the complaint that are merely legal conclusions; and 2) where there are well-pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Kivisto v. Miller, Canfield, Paddock & Stone, PLC, 413 F. App’x 136, 138 (11th Cir. 2011) (per curiam) (citations and internal quotation marks omitted). This is “a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679. If the court determines that “the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct,” the claims are due to be dismissed. Id. at 570. III. Analysis Defendants argue that Plaintiff’s complaint (Doc. # 1-1) is a shotgun pleading. (Docs. # 5 at 7-10; 7 at 6-10). They additionally argue that various of Plaintiff’s claims fail to state claims for relief. (Docs. # 5; 7). A. Shotgun Pleading

“A complaint that fails to comply with Rules 8 and 10 may be classified as a ‘shotgun pleading.’” Luft v. Citigroup Glob. Mkts. Realty Corp., 620 F. App’x 702, 704 (11th Cir. 2015). The Eleventh Circuit has repeatedly and forcefully condemned shotgun pleadings. See Est. of Bass v. Regions Bank, Inc., 947 F.3d 1352, 1356 n.3 (11th Cir. 2020). There are four basic categories of shotgun pleadings: 1) those in which “each count adopts the allegations of all preceding counts”; 2) those that do not re-allege all preceding counts but are “replete with conclusory, vague, and immaterial facts not obviously connected to any particular cause of action”; 3) those that do not separate each cause of action or claim for relief into a different count; and 4) those that assert multiple claims against multiple defendants without specifying which applies to which. Weiland

v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313, 1321-23 (11th Cir. 2015). “The unifying characteristic of all types of shotgun pleadings is that they fail to one degree or another, and in one way or another, to give the defendants adequate notice of the claims against them and the grounds upon which each claim rests.” Id. at 1323.

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Pinyan v. City of Oneonta, Alabama, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pinyan-v-city-of-oneonta-alabama-alnd-2025.