Pittman v. M. Sivels

CourtDistrict Court, E.D. Virginia
DecidedFebruary 23, 2021
Docket3:19-cv-00500
StatusUnknown

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

Bluebook
Pittman v. M. Sivels, (E.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division CLEVIN PITTMAN, Plaintiff. v. Civil Action No. 3:19CV500 M. SIVELS, Defendant. MEMORANDUM OPINION Clevin Pittman, a Virginia inmate proceeding pro se and in forma pauperis, filed this civil action pursuant to 42 U.S.C. § 1983.’ Pittman alleges that Defendant Sivels “stood by the bed and watched [Officer] D.M. York choke [Pittman.]” (ECF No. 13. at 1.)? The matter is now before the Court on the Motion to Dismiss filed by Defendant Sivels. (ECF No. 19.) For the reasons stated below, the Motion to Dismiss will be DENIED WITHOUT PREJUDICE. I. Standard for Motion to Dismiss “A motion to dismiss under Rule |2(b)(6) tests the sufficiency of a complaint: importantly, it does not resolve contests surrounding the facts, the merits of a claim, or the applicability of defenses.” Republican Party of N.C. v. Martin. 980 F.2d 943. 952 (4th Cir.

' The statute provides. in pertinent part: Every person who, under color of any statute . .. of any State . . . subjects. or causes to be subjected. any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights. privileges. or immunities secured by the Constitution and laws. shall be liable to the party injured in an action atlaw.... 42 U.S.C. § 1983. ? The Court employs the pagination assigned to the parties’ submissions by the CM/ECF docketing system. The Court corrects the punctuation. spelling. and capitalization and omits the emphasis in quotations from the parties” submissions.

1992) (citing 5A Charles A. Wright & Arthur R. Miller, Federal Practice and Procedure § 1356 (1990)). In considering a motion to dismiss for failure to state a claim, a plaintiff's well-pleaded allegations are taken as true and the complaint is viewed in the light most favorable to the plaintiff. Mylan Labs.. Inc. v. Matkari, 7 F.3d 1130, 1134 (4th Cir. 1993): see also Martin, 980 F.2d at 952. This principle applies only to factual allegations, however, and “a court considering a motion to dismiss can choose to begin by identifving pleadings that. because they are no more than conclusions, are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662. 679 (2009). The Federal Rules of Civil Procedure “require[] only □□ short and plain statement of the claim showing that the pleader is entitled to relief.” in order to “give the defendant fair notice of what the . . . claim is and the grounds upon which it rests."” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (second alteration in original) (citation omitted). Plaintiffs cannot satisfy this standard with complaints containing only “labels and conclusions” or a “formulaic recitation of the elements of a cause of action.” /d. (citations omitted). Instead, a plaintiff must allege facts sufficient “to raise a right to relief above the speculative level.” id. (citation omitted). stating a claim that is “plausible on its face.” id. at 570. rather than merely “conceivable.” /d. “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.” /gbal. 556 U.S. at 678 (citing Bell At. Corp., 550 U.S. at 556). In order for a claim or complaint to survive dismissal for failure to state a claim. the plaintiff must “allege facts sufficient to state all the elements of [his or| her claim.” Bass v. ELL DuPont de Nemours & Co., 324 F.3d 761, 765 (4th Cir. 2003) (citing Dickson v. Microsoft Corp.. 309 F.3d 193. 213 (4th Cir. 2002): Jodice v. United States, 289 F.3d 270. 281 (4th Cir. 2002)).

Lastly. while the Court liberally construes pro se complaints. Gordon v. Leeke, 574 F.2d 1147, 1151 (4th Cir. 1978), it will not act as the inmate’s advocate and develop, sua sponte, statutory and constitutional claims that the inmate failed to clearly raise on the face of his or her complaint. See Brock v. Carroll, 107 F.3d 241, 243 (4th Cir. 1997) (Luttig, J., concurring); Beaudett v. City of Hampton, 775 F.2d 1274. 1278 (4th Cir. 1985). II. Pittman’s Allegations In his Particularized Complaint. Pittman names M. Sivels. an Officer with the Chesapeake Police Department, as Defendant. (ECF No. 13. at 1.) Pittman alleges the following: Officer M. Sivels stood by the bed and watched [Officer] D.M. York choke me (Clevin Pittman). He had a sworn duty to protect me, but he did not. He violated my 8'" Amendment Rights by not protecting me Clevin Pittman under the Constitution. I... believe under the 8" Amend[ment] it states no harm shall come to another person and to protect and M. Sivels failed that. He allowed me to be choked by his co—worker. When Officer D.M. York was choking me and putting on me Clevin Pittman excessive force, Officer M. Sivels was just standing there watching. It was his duty to protect me and he did not and I believe it is an 8" Amendment violation. (/d. at 1-2 (paragraph numbering omitted).) HI. Analysis In the Motion to Dismiss, Defendant Sivels raises three arguments to support dismissing the Particularized Complaint: 1) that Pittman failed to state a claim of excessive force against him on the basis of bystander liability: 2) that Pittman’s successful recovery would necessarily imply the invalidity of his two state criminal convictions for assault on a law enforcement officer; and, 3) that Defendant Sivels is entitled to qualified immunity.

A. Failure to State a Claim Defendant Sivels argues that Pittman fails to state an Eighth Amendment claim. At this juncture, the Court must presume the truth of all Pittman’s well-pleaded allegations. Afylan Labs., Inc., 7 F.3d at 1134. With respect to the first contention, that Defendant Sivels did not use excessive force, the Court previously determined that Pittman stated a claim for relief sufficient to survive the Court’s screening obligations. Therefore, the Motion to Dismiss will be DENIED on that ground. B. Heck v. Humphrey Next. Defendant Sivels contends that Pittman’s successful recovery would necessarily imply the invalidity of his two state criminal convictions for assault on a law enforcement officer, citing Heck v. Humphrey, 512 U.S. 477, 487 (1994). Defendant Sivels attaches state court records to his Motion to Dismiss showing that Pittman was charged and convicted of assault on an officer for the incident that rests at the heart of this action. (ECF No. 20-1, at 2-5.) However, the Court fails to discern, and Defendant Sivels fails to explain. how the fact that Pittman was convicted for spitting on an officer necessarily precludes a finding that Defendant Sivels may also have violated Pittman’s constitutional rights at or around the same time.

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

Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Crawford v. Marion County Election Board
553 U.S. 181 (Supreme Court, 2008)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Martinez v. City of Albuquerque
184 F.3d 1123 (Tenth Circuit, 1999)
Riddick v. Lott
202 F. App'x 615 (Fourth Circuit, 2006)
Smith v. Smith
589 F.3d 736 (Fourth Circuit, 2009)
LeSueur-Richmond Slate Corp. v. Fehrer
666 F.3d 261 (Fourth Circuit, 2012)
Gravity Inc v. Microsoft Corp
309 F.3d 193 (Fourth Circuit, 2002)
Brock v. Carroll
107 F.3d 241 (Fourth Circuit, 1997)
Williams v. Wilkerson
90 F.R.D. 168 (E.D. Virginia, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
Pittman v. M. Sivels, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pittman-v-m-sivels-vaed-2021.