Reich v. Silver Bow Detention Center

CourtDistrict Court, D. Montana
DecidedJanuary 10, 2025
Docket2:24-cv-00052
StatusUnknown

This text of Reich v. Silver Bow Detention Center (Reich v. Silver Bow Detention Center) 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
Reich v. Silver Bow Detention Center, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BUTTE DIVISION

ROBERT LEE REICH, CV 24-52—-BU-DWM Plaintiff, vs. OPINION and ORDER DETENTION OFFICER JOHN SULLIVAN, CHIEF MARK JOHNSON, CAPTAIN RAY VAUGHN, and THE CITY AND COUNTY OF BUTTE-SILVER BOW, Defendants.

In June 2024, Plaintiff Robert Reich, a state inmate proceeding without counsel, filed a civil rights complaint under 42 U.S.C. § 1983, alleging his constitutional rights were violated when he was not provided with toothpaste at the Butte-Silver Bow Detention Center for more than seven weeks. (Doc. 1.) Defendants Detention Officer John Sullivan, Chief Mark Johnson, and Captain Ray Vaughn were ordered to answer,' (see Doc. 9), and now seek to dismiss Reich’s complaint for failure to state a claim under Rule 12(b)(6) of the Federal

' Reich subsequently requested to amend to add Butte-Silver Bow City and County. (See Doc. 15.) Because that request was timely, see Fed. R. Civ. P. 15(a)(1), it is granted. However, Reich’s attempts to amend his complaint through an Amended Information, (Doc. 11); Notice of Updated Information, (Doc. 16); and Motion for Notice of Retaliation, (Doc. 34), are denied.

Rules of Civil Procedure, (Doc. 17). With limited exception, that motion is denied. LEGAL STANDARD To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “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.” Jd. Dismissal is appropriate “where there is no cognizable legal theory or an absence of sufficient facts alleged to support a cognizable legal theory.” L.A. Lakers, Inc. v. Fed. Ins. Co., 869 F.3d 795, 800 (9th Cir. 2017) (internal quotation marks omitted). While pro se complaints are construed liberally, Hebbe v. Pliler, 627 F.3d 338, 342 (9th Cir. 2010), “a liberal construction of a pro se complaint . . . does not mean that the court will supply essential elements of a claim that are absent from the complaint,” Boquist v. Courtney, 32 F.4th 764, 774 (9th Cir. 2022). While courts should generally permit pro se litigants an opportunity to amend their complaint to state a plausible claim, see United States v. Corinthian Colleges, 655 F.3d 984, 995 (9th Cir. 2011) (“[D]ismissal without leave to amend is improper unless it is clear, upon de novo review, that the complaint could not be saved by any amendment.”) (internal

quotation marks omitted), “[c]ourts are not required to grant leave to amend if □ complaint lacks merit entirely,” Lopez v. Smith, 203 F.3d 1122, 1129 (9th Cir. 2000). The facts are taken from Reich’s Complaint, (see Doc. 1), and are assumed to be true and construed in the light most favorable to him, Ariix, LIC v. NutriSearch Corp., 985 F.3d 1107, 1114 (9th Cir. 2021). ANALYSIS Section 1983 confers a tort remedy upon individuals “whose constitutional rights have been violated by state officials acting ‘under color of’ law.” Whalen v. MeMullen, 907 F.3d 1139, 1145 (9th Cir. 2018) (quoting 42 U.S.C. § 1983). Consistently, “[t]o state a claim under § 1983, a plaintiff must allege two essential elements: (1) that a right secured by the Constitution or laws of the United States

was violated, and (2) that the alleged violation was committed by a person acting under the color of State law.” Benavidez v. Cnty. of San Diego, 993 F.3d 1134, 1144 (9th Cir. 2021) (internal quotation marks omitted). Defendants argue that: (1) Reich’s Eighth Amendment claim fails as a matter of law because he was a pretrial detainee, not a convicted prisoner; (2) he does not allege a policy, practice, or custom as the moving force behind any of the claimed constitutional violations; (3) he cannot pursue punitive damages or have his bail reduced; and (4) his claims fail under the Fourteenth Amendment as well. Defendants are correct as to (3); at this stage of the proceeding, their other

5 .

arguments lack merit. I. Eighth Amendment Defendants first argue that Reich’s claims regarding a lack of toothpaste cannot proceed under the Eighth Amendment because he was a pretrial detainee at the time of the alleged deprivation, not a convicted prisoner. Indeed, the conditions of confinement in the pretrial detainee context are evaluated under the Fourteenth Amendment Due Process Clause, not the Eighth Amendment. Gordon

v. Cnty. of Orange, 888 F.3d 1118, 1124-25 (9th Cir. 2018); see Norbert v. City & Cnty. of SF, 10 F.4th 918, 928 (9th Cir. 2021). But it would elevate form over substance to dismiss a pro se prisoner’s complaint for merely citing the incorrect constitutional provision. As recognized by Defendants in their briefing, the

gravamen of Reich’s complaint—Defendants’ failure to provide constitutionally adequate conditions of confinement through the provision of toothpaste to inmates—is sufficiently pled. See Fed. R. Civ. P. 8(a)(2) (requiring a pleading contain “a short and plain statement of the claim showing that the pleader is entitled to relief”). Thus, while he cannot proceed under the Eighth Amendment, Reich’s claim survives this challenge. II. Policy, Practice, or Custom Defendants further argue that Reich cannot proceed in his claims against the County and City or against any of the individual defendants in their official

capacities because a finding of municipal liability requires one of the following: “(1) an official policy; (2) a pervasive practice or custom; (3) a failure to train, supervise, or discipline; or (4) a decision or act by a final policymaker.” Horton v. City of Santa Maria, 915 F.3d 592, 602-03 (9th Cir. 2019); see also Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 695 (1978). This challenge fails for two

reasons. First, while Reich checked the “official capacity” boxes on the complaint form provided by the Court, (see Doc. 1 at 2—3), the capacity in which a defendant is sued in the civil rights context is a complicated matter. Rather than look solely to this “check box,” the Court, like Defendants’ themselves, considers the nature of the factual allegations contained therein.

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