Ratcliff v. Edge

CourtDistrict Court, M.D. Florida
DecidedSeptember 29, 2023
Docket8:22-cv-02782
StatusUnknown

This text of Ratcliff v. Edge (Ratcliff v. Edge) 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
Ratcliff v. Edge, (M.D. Fla. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION DAVID MARC RATCLIFF, Plaintiff, v. Case No. 8:22-cv-2782-TPB-CPT ALEXANDER EDGE, et al., Defendants. a ORDER This action is based on both the alleged use of excessive force, including blows to Ratcliffs head and bites from “K-9 Yoda,” and the alleged failure to intervene to stop the use of excessive force. Ratcliff sues two groups of defendants: deputies of the Pinellas County Sheriffs Office (““PCSO Defendants”) and officers of the Clearwater Police Department (“CPD Defendants”). The defendants removed the action from state court. I. BACKGROUND Both groups of defendants move (Docs. 7 and 17) to dismiss the complaint under Rule 12(b)(6), Federal Rules of Civil Procedure. The PCSO Defendants seek dismissal because (1) Ratcliff failed to timely effect service of process, (2) no PCSO Defendant committed a constitutional violation, and (3) each PSCO Defendant is entitled to qualified immunity. The CPD Defendants seek dismissal because (1) Ratcliff failed to timely effect service of process, (2) the

complaint is a prohibited “shotgun pleading,” and (3) both no CPD Defendant committed a constitutional violation and each is entitled to qualified immunity. An earlier order (Doc. 31) dismisses Defendant Extine because she was never served but otherwise rejects dismissing the action based on untimely service. Also, the earlier order (Doc. 31) notes (1) that, in the complaint, Ratcliff refers to the existence of “video footage” taken by a bystander, by a police helicopter, and by officers’ body cameras — evidence Ratcliff asserts will support his claims; (2) that both groups of defendants move to dismiss (Docs. 7 and 17) and support their motions with the video footage referenced in the complaint; (3) that the defendants request the court take judicial notice of the state court records showing Ratcliff’s pending criminal charges that both preceded his arrest and resulted from his arrest: (4) that Ratcliff does not object to the defendants exhibits and, moreover, he attaches additional exhibits to his opposition (Doc. 25) to the motions to dismiss; and (5) that, as a consequence, under Rule 12(d) the motions to dismiss must proceed as motions for summary judgment: “Tf, on a motion under Rule 12(b)(6) or 12(c), matters outside the pleadings are presented to and not excluded by the court, the motion must be treated as one for summary judgment under Rule 56.” Lastly, the earlier order (Doc. 31) (1) explains that this action will proceed under Rule 56, Federal Rules of Civil Procedure, for summary judgment; (2) explains how a summary judgment under Rule 56 differs from a motion to

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dismiss under Rule 12; (3) cautions Ratcliff about the finality of summary judgment; and (4) affords the parties an opportunity to supplement their arguments. In accord with that order, Ratcliff and the two groups of defendants filed their supplements. (Docs. 35-38, respectively) Consequently, this action is ripe for decision on both of the converted motions for summary judgment. (Docs. 7 and 17, respectively) Hi, MOTIONS FOR SUMMARY JUDGMENT Entitlement to summary judgment depends on the undisputed facts. Under Rule 56(a), Federal Rules of Civil Procedure, “[t]he court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to a judgment as a matter of law.” The party moving for summary judgment has the initial burden of showing the absence of a genuine issue of material fact. Johns v. Jarrard, 927 F.2d 551, 555 (11th Cir. 1991). Viewed in the light most favorable to the non-moving party, the documents must show the absence of a genuine issue of material fact and the moving party’s entitlement to judgment as a matter of law. See generally, Allen v. Tyson Foods, Inc., 121 F.3d 642 (11th Cir. 1997); Jeffery v. Sarasota White Sox, Inc., 64 F.3d 590 (11th Cir. 1995). Even though allegations in a pro se complaint are held to a less stringent standard than a formal pleading drafted by a lawyer (Haines v. Kerner, 404 U.S. 519 (1972) (per curiam); Tannenbaum v. United States, 148 F.3d 1262 (11th Cir. 1998)), the plaintiffs

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allegation must have factual support. “The mere existence of a scintilla of evidence in support of the plaintiffs position will be insufficient; there must be evidence on which the jury could reasonably find for the plaintiff.”. Burger King Corp, v. Weaver, 169 F.3d 1310, 13821 (11th Cir.) reh’g and suggestion for reh’g en bane denied, 182 F.3d 938 (11th Cir. 1999). Once the movant presents evidence that, if not controverted, would entitle the movant to judgment as a matter of law, the burden shifts to the non-moving party to assert specific facts demonstrating a genuine issue of material fact. Anderson. v. Liberty Lobby, Inc., 477 U.S. 242, 250 (1986); Pennington v. City of Huntsville, 261 F.3d 1262 (11th Cir. 2001). If one party’s claim is implausible, that party must present more persuasive facts than necessary to show that a genuine factual issue exists. Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986). See also Cuesta v. School Bd. of Miami-Dade County, 285 F.8d 962, 970 (11th Cir. 2002) (‘A court need not permit a case to go to a jury, however, when the inferences that are drawn from the evidence, and upon which the non- movant relies, are ‘implausible.”). A material issue of fact is one that affects the outcome of the litigation and requires a trial to resolve the differing versions of the truth. Anderson, 477 U.S. at 248. Ratcliff and the defendants disagree on the amount of and the necessity for the use of force. The defendants’ “... version of events (unsurprisingly) differs substantially from [the plaintiff’s] version. When things are in such a

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posture, courts are required to view the facts and draw reasonable inferences in the light most favorable to the party opposing the [summary judgment] motion.” Scott v. Harris, 550 U.S. 372, 378 (2007). However, “[w]hen opposing parties tell two different stories, one of which is blatantly contradicted by the record, so that no reasonable jury could believe it, a court should not adopt that version of the facts for purposes of ruling on a motion for summary judgment.” Scott, 550 U.S. at 380. See also Feliciano v. City of Miami Beach, 707 F.3d 1244, 1253 (11th Cir. 2013) (explaining that for evidence to be discounted at summary judgment, it must be more than simply self-serving or unsubstantiated; the evidence must be “blatantly contradicted by the record, blatantly inconsistent, or incredible as a matter of law, meaning that it relates to facts that could not have possibly been observed or events that are contrary to the laws of nature’); Both Ratcliff and all the defendants rely upon videos taken by a bystander, by a police helicopter, and by officers’ body cameras.

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Related

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64 F.3d 590 (Eleventh Circuit, 1995)
Allen v. Tyson Foods, Inc.
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556 F.3d 1283 (Eleventh Circuit, 2009)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Brown v. City of Huntsville, Ala.
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Pourmoghani-Esfahani v. Gee
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Janet Feliciano v. City of Miami Beach
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Mobley v. Palm Beach County Sheriff Department
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Bluebook (online)
Ratcliff v. Edge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ratcliff-v-edge-flmd-2023.