Rios v. Dolan

CourtDistrict Court, E.D. Wisconsin
DecidedFebruary 2, 2022
Docket1:21-cv-01417
StatusUnknown

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

Bluebook
Rios v. Dolan, (E.D. Wis. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

SALVADOR RIOS,

Plaintiff,

v. Case No. 21-C-1417

OFFICER DOLAN, OFFICER THOMPSON, and ANNALISE MARIA MARTIN,

Defendants.

SCREENING ORDER

Plaintiff Salvador Rios, who is currently serving a state prison sentence at Dodge Correctional Institution and representing himself, filed a complaint under 42 U.S.C. §1983, alleging that his civil rights were violated. This matter comes before the Court on Rios’ motion for leave to proceed without prepaying the full filing fee and to screen the complaint. MOTION TO PROCEED WITHOUT PREPAYING THE FILING FEE Rios has requested leave to proceed without prepaying the full filing fee (in forma pauperis). A prisoner plaintiff proceeding in forma pauperis is required to pay the full amount of the $350.00 filing fee over time. See 28 U.S.C. §1915(b)(1). Rios has filed a certified copy of his prison trust account statement for the two-month period immediately preceding the filing of his complaint, instead of the six-month period as required under 28 U.S.C. §1915(a)(2). The Court assessed and Rios has paid an initial partial filing fee of $21.64. Rios’ motion for leave to proceed without prepaying the filing fee will be granted. SCREENING OF THE COMPLAINT The Court has a duty to review any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity, and dismiss any complaint or portion thereof if the prisoner has raised any claims that are legally “frivolous or malicious,”

that fail to state a claim upon which relief may be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §1915A(b). In screening a complaint, the Court must determine whether the complaint complies with the Federal Rules of Civil Procedure and states at least plausible claims for which relief may be granted. To state a cognizable claim under the federal notice pleading system, a plaintiff is required to provide a “short and plain statement of the claim showing that [he] is entitled to relief.” Fed. R. Civ. P. 8(a)(2). It must be at least sufficient to provide notice to each defendant of what he or she is accused of doing, as well as when and where the alleged actions or inactions occurred, and the nature and extent of any damage or injury the actions or inactions caused. “The pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544,

555 (2007)). “The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “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.” Id. at 556. “[T]he complaint’s allegations must be enough to raise a right to relief above the speculative level.” Id. at 555 (internal quotations omitted). ALLEGATIONS OF THE COMPLAINT Rios alleges that, on August 20, 2021, Defendant Officers Dolan and Thompson, knocked on his front door, informed him they had a warrant for his arrest, and arrested him. Rios asserts that he asked the officers to handcuff him in the front because he is “a bigger and broad gentleman.”

Dolan allegedly told him no and explained that they would use two sets of handcuffs. Rios alleges that they “continued to both struggle,” but he does not clarify what he means by that characterization. Rios allegedly asked the officers if he could give his car keys to one of his managers, but they said no. Rios asserts that he then “[i]nvoked his 1st, 2nd, 3rd, 4th, and 5th [amendment rights].” According to Rios, Dolan stated shortly thereafter, “I think we cuffed him to[o] tight.” Dkt. No. 1 at 3. Rios asserts that when he was put in the police vehicle, he felt “a sudden pop in his left shoulder and somewhat like [a] tear or strain in his right shoulder.” Rios does not state whether he notified the officers of his pain. After Rios arrived at the jail, he asked a non-Defendant officer if he could be uncuffed because the handcuffs were too tight. According to Rios, the officer

uncuffed him. Rios asserts that he “showed her the imprint and the teeth of the cuffs on his wrists.” The officer allegedly told Rios, “I could see why they discriminated you being Hispanic, tattooed and a bigger guy.” Id. Rios asserts that he has been on nerve pain medication since his arrest. Dkt. No. 1 at 4. Rios also asserts that he later found out that Defendant Annalise Martin, an employee of Spectrum, “had [filed] a criminal complaint which all allegations were false exception of the misunderstanding via email.” Dkt. No. 1 at 2, 4. THE COURT’S ANALYSIS First, Rios fails to state a claim against Martin, who he identifies as an employee of Spectrum. He would “like her incarcerated for lying excessively about allegations using the hearsay law against [him] knowing[] [that he] was on probation.” Dkt. No. 1 at 5. But a plaintiff

“may not bring a § 1983 claim against a private citizen who is not acting under the color of state law.” Patel v. Heidelberger, 6 F. App’x 436, 437 (7th Cir. 2001). Because nothing in Rios’ complaint suggests that Martin’s actions may be fairly treated as that of the State itself, he may not bring a §1983 claim against her. See id. at 437-38. Next, Rios’ claims that officers used excessive force while arresting him arise under the Fourth Amendment. Graham v. Connor, 490 U.S. 386, 394 (1989); see Tennessee v. Garner, 471 U.S. 1, 7–8 (1985). The Court applies an objective reasonableness test and considers the reasonableness of the force based on the events confronting the officers at the time. See Horton v. Pobjecky, 883 F.3d 941, 949–50 (7th Cir. 2018) (citing Graham, 490 U.S. at 396–97). This test balances “the nature and quality of the intrusion on the individual’s Fourth Amendment interests

against the countervailing governmental interests at stake.” Id. at 949 (quoting Graham, 490 U.S. at 396). Rios fails to state a claim upon which relief can be granted because the Court cannot reasonably infer from his allegations that the officers acted unreasonably when they handcuffed him. Although they denied Rios’ request that he be handcuffed in front, they accommodated his size by using two sets of handcuffs rather than one. Given safety concerns associated with handcuffing individuals in front rather than in back, their decision was not unreasonable.

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Related

Tennessee v. Garner
471 U.S. 1 (Supreme Court, 1985)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
James Horton v. Frank Pobjecky
883 F.3d 941 (Seventh Circuit, 2018)
Patel v. Heidelberger
6 F. App'x 436 (Seventh Circuit, 2001)

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Rios v. Dolan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rios-v-dolan-wied-2022.