Renck v. Novak

CourtDistrict Court, D. Nevada
DecidedMay 20, 2020
Docket3:19-cv-00622
StatusUnknown

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

Bluebook
Renck v. Novak, (D. Nev. 2020).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 9 STEVEN RENCK,

10 Plaintiff, Case No. 3:19-CV-00622-RCJ-CLB 11 vs. ORDER 12 GREG NOVAK, 13 Defendant. 14

15 Defendant moves to dismiss the case for lack of subject-matter jurisdiction based on 16 sovereign immunity and for failure to state a claim. Finding numerous but potentially curable 17 deficiencies with the complaint, the Court dismisses the claims against Defendant with leave to 18 amend. 19 FACTUAL BACKGROUND 20 In his complaint, Plaintiff alleges the following: In August 2018, he was involved in a 21 vehicular accident causing him significant injuries. (ECF No. 1 Ex. A.) The accident occurred on 22 Interstate 11 in Nevada near Boulder City. (Id.) The interstate was undergoing construction with 23 insufficient safety precautions including inadequate signage. (Id.) Compounding the problem, the 24 GPS mapping services were misdirecting traffic. (Id.) Defendant could have prevented the accident 1 if he undertook “a reasonable amount of controls” and issued advisories, but he failed to do so. 2 (Id.) Defendant has a duty to “oversee and implement responsible safety precaution and procedures 3 necessary to ensure the safe travel on” interstates in Nevada. (Id.) Plaintiff seeks monetary 4 damages but does not request injunction relief. (Id.) 5 Based on these allegations, Plaintiff claims that Defendant is liable without specifying any 6 cause of action under federal or state law. (Id.) Defendant moves to dismiss the case under 7 Rule 12(b) for a lack of subject-matter jurisdiction based on sovereign immunity and for failure to 8 state a claim. 9 LEGAL STANDARD 10 I. Fed. R. Civ. P. 12(b)(1) 11 “Sovereign immunity is jurisdictional in nature.” F.D.I.C. v. Meyer, 510 U.S. 471, 475 12 (1994). Therefore, claims that sovereign immunity has not been waived fall under Fed. R. Civ. P.

13 12(b)(1). When filing a motion to dismiss under Rule 12(b)(1), a party may attack subject-matter 14 jurisdiction either facially or factually. Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th 15 Cir. 2004). A facial attack is analyzed using a standard similar to that used in a Rule 12(b)(6) 16 motion—the Court analyzes jurisdiction from the face of the complaint and accepts all facts alleged 17 as true. Id. In the case of a factual attack, the Court may review evidence and make findings of fact 18 regarding jurisdiction without converting the motion into a motion for summary judgment. Id. 19 (citing Savage v. Glendale Union High Sch., 343 F.3d 1036, 1039 n.2 (9th Cir. 2003)). If a court 20 determines that it lacks subject-matter jurisdiction, then its authority is limited to making that 21 finding and dismissing the claims. Arbaugh v. Y&H Corp., 546 U.S. 500, 514 (2006). Finally, 22 “jurisdictional questions ordinarily must precede merits determinations in dispositional order.”

23 Sinochem Int’l Co. Ltd. v. Malaysia Shipping Corp., 549 U.S. 422, 431 (2007). 24 /// 1 II. Fed. R. Civ. P. 12(b)(6) 2 Rule 12(b)(6) mandates that a court dismiss a cause of action that fails to state a claim upon 3 which relief can be granted. When considering a motion to dismiss under Rule 12(b)(6), dismissal 4 is appropriate only when the complaint does not give the defendant fair notice of a legally 5 cognizable claim and the grounds on which it rests. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 6 555 (2007). In considering whether the complaint is sufficient to state a claim, the court will take 7 all material allegations as true and construe them in the light most favorable to the plaintiff. NL 8 Indus., Inc. v. Kaplan, 792 F.2d 896, 898 (9th Cir. 1986). 9 The court, however, is not required to accept as true allegations that are merely conclusory, 10 unwarranted deductions of fact, or unreasonable inferences. Sprewell v. Golden State Warriors, 11 266 F.3d 979, 988 (9th Cir. 2001). Nor must a court accept formulaic recitations of a cause of 12 action with conclusory allegations. Ashcroft v. Iqbal, 556 U.S. 662, 677–79 (2009) (citing

13 Twombly, 550 U.S. at 556) Instead, the plaintiff must “plead[] factual content that allows the court 14 to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 15 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). That is, a plaintiff must not only specify or 16 imply a cognizable legal theory, but also must also provide enough facts that the court can 17 determine whether there is any basis for relief under the legal theory specified or implied, assuming 18 the facts are as alleged. 19 Upon granting a motion to dismiss, a court must then determine whether to allow leave to 20 amend the complaint. Leave to amend should be granted unless “amendment would be futile.” 21 DeSoto v. Yellow Freight Sys., Inc., 957 F.2d 655, 658 (9th Cir. 1992) (citing Reddy v. Litton 22 Indus., 912 F.2d 291, 296 (9th Cir. 1990)). That is, dismissal without leave to amend is appropriate

23 only where “the court determines that the allegation of other facts consistent with the challenged 24 pleading could not possibly cure the deficiency.” Schreiber Distrib. Co. v. Serv-Well Furniture 1 Co., Inc., 806 F.2d 1393, 1401 (9th Cir. 1986) (citing Bonanno v. Thomas, 309 F.2d 320, 322 (9th 2 Cir. 1962)). 3 ANALYSIS 4 Defendant Novak’s motion to dismiss provides five arguments as to why Plaintiff’s 5 complaint should be dismissed. The Court addresses each of these arguments in turn, finding that 6 deficiencies in the complaint require dismissal, but granting leave to amend as such amendment is 7 not clearly futile. 8 I. Plaintiff did not demonstrate waiver of sovereign immunity 9 For suit against the federal government to be proper, the United States must “unequivocally 10 express[]” waiver of sovereign immunity and consent to the action. Dunn & Black, P.S. v. United 11 States, 492 F.3d 1084, 1087–88 (9th Cir. 2007). A plaintiff bears the burden of demonstrating 12 waiver of sovereign immunity—generally by pointing to a statute which expressly grants waiver

13 for the type of claim being brought. See, e.g., Holloman v. Watt, 708 F.2d 1399, 1401 (9th Cir. 14 1983). Here, Plaintiff’s complaint does not identify any such statute. 15 Plaintiff’s response to the motion to dismiss identifies the Federal Tort Claims Act (FTCA) 16 as at least one basis for his claim. (ECF No.

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Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
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Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Nl Industries, Inc. v. Stuart M. Kaplan
792 F.2d 896 (Ninth Circuit, 1986)
John Desoto v. Yellow Freight Systems, Inc.
957 F.2d 655 (Ninth Circuit, 1992)
Dunn & Black, P.S. v. United States
492 F.3d 1084 (Ninth Circuit, 2007)
Bonanno v. Thomas
309 F.2d 320 (Ninth Circuit, 1962)
Chang v. Chen
80 F.3d 1293 (Ninth Circuit, 1996)
Sprewell v. Golden State Warriors
266 F.3d 979 (Ninth Circuit, 2001)
Safe Air for Everyone v. Meyer
373 F.3d 1035 (Ninth Circuit, 2004)
Holloman v. Watt
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Reddy v. Litton Industries, Inc.
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