Richards v. Las Vegas Metropolitan Police Department

CourtDistrict Court, D. Nevada
DecidedApril 15, 2022
Docket2:19-cv-02043
StatusUnknown

This text of Richards v. Las Vegas Metropolitan Police Department (Richards v. Las Vegas Metropolitan Police Department) 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
Richards v. Las Vegas Metropolitan Police Department, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Sommer Richards, Case No.: 2:19-cv-02043-JAD-BNW

4 Plaintiff

5 v. Order Granting in Part Motion for Summary Judgment and Closing Case 6 Ondre Wills and Las Vegas Metropolitan Police Department, [ECF No. 23] 7 Defendants 8

9 Sommer Richards brings this excessive-force suit against the Las Vegas Metropolitan 10 Police Department and one of its officers, Ondre Wills. The suit arises out of Wills’s non-fatal 11 shooting of Richards after reports that Richards was following people through a mobile-home 12 park while threateningly wielding a shovel. Wills arrived at the scene without backup and 13 repeatedly instructed Richards to put the shovel down, but she ignored those commands. When 14 Richards—shovel in hand—started advancing toward a bystander, Wills shot her. Richards 15 survived the shooting and brings an excessive-force claim against Wills and state-law negligence 16 and intentional-infliction-of-emotional-distress claims against both Wills and Metro. The 17 defendants move for summary judgment on all three claims, arguing that Wills is entitled to 18 qualified immunity. Because I find that Wills acted reasonably under the totality of the 19 circumstances, he is entitled to qualified immunity on Richards’s excessive-force claim. So I 20 grant Wills summary judgment on it. I then decline to exercise supplemental jurisdiction over 21 the remaining state-law claims, dismiss them without prejudice to Richards’s ability to refile 22 them in state court, and close this case. 23 1 Background1 2 On the evening of May 12, 2018, Richards “was experiencing an emotional and 3 psychological episode” as she walked barefoot through a mobile-home park while carrying a 4 shovel.2 Emergency services received calls from two concerned citizens, Maria Montoy (who 5 reported that Richards was threatening her and her family) and Olivia Perez,3 reporting “that a

6 woman was acting erratically and swinging a shovel in circles.”4 During her 911 call, Perez also 7 reported that Richards had hit Perez’s fiancé’s car with the shovel and was following the couple 8 through the neighborhood.5 Officer Wills responded to the calls and arrived at the scene.6 9 Body-worn camera (BWC) footage captured the events from Wills’s arrival until just before 10 Richards received medical attention.7 11 When Wills exited his vehicle, he immediately drew his firearm and pointed it at 12 Richards, Perez and her fiancé were standing nearby, and Richards was holding a shovel and 13 standing in the street in front of all three of them.8 Wills immediately ordered Richards to drop 14

1 These facts are derived from Richards’s allegations, depositions, and my observations from the 16 footage recorded by Wills’s BWC. ECF No. 23-11 at 3 (CD manually filed at ECF No. 24). See Scott v. Harris, 550 U.S. 372, 380 (2007) (holding that courts should rely on video evidence, 17 when possible, to determine reasonableness in excessive-force cases). The facts are undisputed unless otherwise noted. 18 2 ECF No. 1 at ¶ 15. 19 3 ECF No. 23-5; ECF No. 23-6 (Montoy’s and Perez’s deposition transcripts). 20 4 ECF No. 1 at ¶ 15. There was initially some ambiguity about the object that Richards was carrying, with witnesses identifying it as a broom or a cooking pan, before ultimately concluding 21 it was a shovel. 5 ECF No. 23-6 at 6–7. 22 6 ECF No. 23-11 at 3 (Wills’s BWC at 05:20:20). 23 7 Id. 8 Id. 1 the shovel, but she didn’t comply, and Wills told Perez and her fiancé to get behind him.9 Wills, 2 who arrived on the scene without backup, then communicated over his police radio that 3 “[Richards] is not complying” and requested backup units to respond.10 Throughout the 4 encounter, Wills told Richards at least 14 times to drop the shovel, but she didn’t acknowledge 5 Wills’s commands and appeared to be talking to herself.11 Wills also told Richards to “step

6 back,”12 said “I don’t want to shoot you,”13 and warned her repeatedly that “if you take one more 7 step, I will shoot you.”14 8 About 15 seconds after one such warning, Perez walked around Wills’s car and started 9 walking up the sidewalk past Richards, who then pointed at Perez and advanced toward her.15 10 Richards then shouted “drop the shovel” one last time, and when Richards didn’t comply, Wills 11 fired seven shots, some of which hit Richards, who was standing near the middle of the street.16 12 Perez testified in her deposition that she “felt in danger right before [Wills] shot” “because 13 [Richards] had chased [Perez and her fiancé] down the street with a shovel.”17 Wills 14 communicated on his radio that shots had been fired.18 Richards dropped the shovel and fell to 15 the ground.19 Wills instructed her to roll over onto her stomach, and Richards complied; she

16 9 Id. (Wills’s BWC at 05:20:26). 17 10 Id. (Wills’s BWC at 05:20:36). 18 11 Id. (Wills’s BWC at 05:20:26, 05:20:54, 05:21:08, 05:21:24, 05:21:32). 12 Id. (Wills’s BWC at 05:20:48, 05:20:54, 05:21:24). 19 13 Id. (Wills’s BWC at 05:20:48). 20 14 Id. (Wills’s BWC at 05:21:02, 05:21:14). 21 15 Id. (Wills’s BWC at 05:21:29). 16 Id. (Wills’s BWC at 05:21:29–05:21:35). 22 17 ECF No. 23-6 at 10. 23 18 ECF No. 23-11 at 3 (Wills’s BWC at 05:21:36). 19 Id. 1 then rolled onto her back again and remained in that position until she received medical 2 attention.20 Richards survived the shotting and filed this lawsuit, and I later granted in part the 3 defendants’ motion to dismiss, leaving only three claims.21 The defendants now move for 4 summary judgment on those remaining claims.22

5 Discussion 6 I. Legal standard 7 Summary judgment is appropriate when the pleadings and admissible evidence “show 8 that there is no genuine issue as to any material fact and that the movant is entitled to judgment 9 as a matter of law.”23 “By its very terms, this standard provides that the mere existence of some 10 alleged factual dispute between the parties will not defeat an otherwise properly supported 11 motion for summary judgment; the requirement is that there be no genuine issue of material 12 fact.”24 A fact is material if it could affect the outcome of the case.25 13 On summary judgment, the court must view all facts and draw all inferences in the light 14 most favorable to the nonmoving party.26 So the parties’ burdens on an issue at trial are critical.

15 When the party moving for summary judgment would bear the burden of proof, “it must come 16 forward with evidence [that] would entitle it to a directed verdict if the evidence went 17 18 20 Id. (Wills’s BWC at 05:21:41–05:24:08). 19 21 ECF No. 6; ECF No. 16. 20 22 ECF No. 23. 23 See Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986) (citing Fed. R. Civ. P. 56(c)). The 21 court’s ability to grant summary judgment on certain issues or elements is inherent in FRCP 56. See Fed. R. Civ. P. 56(a). 22 24 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248–49 (1986). 23 25 Id. at 249. 26 Kaiser Cement Corp. v. Fischbach & Moore, Inc., 793 F.2d 1100, 1103 (9th Cir. 1986).

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Richards v. Las Vegas Metropolitan Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richards-v-las-vegas-metropolitan-police-department-nvd-2022.