Rivera v. Rosaio

CourtDistrict Court, D. Delaware
DecidedMarch 28, 2023
Docket1:20-cv-01758
StatusUnknown

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

Bluebook
Rivera v. Rosaio, (D. Del. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MICHAEL A. RIVERA, Plaintiff,

v. Civ. No. 20-1758-GBW NEW CASTLE COUNTY PD, et al., Defendants. :

Michael A. Rivera, James T. Vaughn Correctional Center, Smyrna, Delaware, Pro Se Plaintiff. Daniel A. Griffith, Whiteford Taylor Preston LLC, Wilmington, Delaware. Counsel for Defendants.

MEMORANDUM OPINION

March 2-6 , 2023 Wilmington, Delaware

Se Wit WILLIAMS, U.S. District Judge: I. INTRODUCTION Plaintiff Michael A. Rivera, an inmate confined at the James T. Vaughn Correctional Center Institution filed this action pursuant to 42 U.S.C. § 1983. (DI. 2, 8). He appears pro se and has been granted leave to proceed in forma pauperis. (D.I. 6). Defendants move to dismiss the Complaint pursuant to Fed. R. Civ. P. 12(b)(6). (D.I. 33). The matter is fully briefed. Plaintiff has also requested appointed counsel. (D.I. 40). Il. BACKGROUND The Complaint was docketed on December 23, 2020. (D.I. 2). In the Complaint, Plaintiff named as Defendants the New Castle County Police Department (“NCCPD”) and several John Doe Defendant NCCPD police officers. (/d.). Plaintiff asserted constitutional claims under § 1983 for illegal search and seizure and excessive force following a December 26, 2018 traffic stop during which Plaintiff and the passenger in his car were arrested. (D.I. 2, 8). Plaintiff was charged with several drug and traffic offenses, but the charges were later nolle prossed. (D.J. 8). For relief, Plaintiff requested damages, and declaratory relief. (D.I. 2 at 4).

| Plaintiff filed an addendum to the Complaint. (D.I. 8). References herein to “the Complaint,” refer to both the Complaint a the addendum.

On August 16, 2021, the Court screened the Complaint and supplement pursuant to 28 U.S.C. §§ 1915(e)(2) and 1915A(a). (D.I. 9). The Court dismissed the claims against the NCCPD, identified what appeared to be cognizable and non- frivolous Fourth Amendment and excessive force claims against the Doe Defendants, and entered a service order upon the NCCPD for the sole purpose of identifying the Doe Defendants. (D.I. 9, 10). On November 12, 2021, the NCCPD filed a notice identifying the Doe Defendants as Corporal Andrew Rosaio (“Rosaio”), Officer Joseph Mihalyi (“Mihalyi”), Master Corporal Silvio Martin (“Martin”), Sergeant Bradley Landis (“Landis”) and Officer Kenneth Guarino (“Guarino”). (D.I. 15). By Order issued

on December 28, 2021, the caption of the Complaint was amended, and Plaintiff

was directed to return U.S. Marshal-285 forms for each Defendant so that the United States Marshal could serve them. (D.I. 17). On March 3, 2022, counsel for Defendants entered an appearance. (D.I. 21). Defendants now move to dismiss the Complaint as time-barred and for failure to state a claim. (D.I. 33, 34). Plaintiff

opposes dismissal. (D.I. 35). LEGAL STANDARD In reviewing a motion to dismiss filed under Fed. R. Civ. P. 12(b)(6), the Court must accept all factual allegations in a complaint as true and take them in the light most favorable to Plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007).

Because Plaintiff proceeds pro se, his pleading is liberally construed and his Complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson, 551 U.S. at 94. A Rule 12(b)(6) motion may be granted only if, accepting the well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the complainant, a court concludes that those allegations “could not raise a claim of entitlement to relief.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 558 (2007). “Though ‘detailed factual allegations’ are not required, a complaint must do more than simply provide ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action.’” Davis v. Abington Mem'l Hosp., 765 F.3d 236, 241 (3d Cir. 2014) (quoting Twombly, 550 U.S. at 555). The Court is “not required to credit bald assertions or legal conclusions improperly alleged in the complaint.” In re Rockefeller Ctr. Props., Inc. Sec. Litig., 311 F.3d 198, 216 (3d Cir. 2002). A complaint may not be dismissed, however, “for imperfect statement of the legal theory supporting the claim asserted.” Johnson v. City of Shelby, 574 U.S. 10, 11 (2014). A complainant must plead facts sufficient to show that a claim has “substantive plausibility.” Jd. at 12. That plausibility must be found on the face of the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “A claim has facial plausibility when the [complainant] pleads factual content that allows the court to

draw the reasonable inference that the [accused] is liable for the misconduct alleged.” Jd. Deciding whether a claim is plausible will be a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. at 679. IV. DISCUSSION Defendants argue that Plaintiff's claims are time-barred by the statute of limitations. For purposes of the statute of limitations, 42 U.S.C. § 1983 claims are characterized as personal injury actions. Wilson v. Garcia, 471 U.S. 261, 275 (1985). In Delaware, § 1983 claims are subject to a two-year limitations period. See 10 Del. C. § 8119; Johnson v. Cullen, 925 F. Supp. 244, 248 (D. Del. 1996). Accordingly, that statute of limitations of Plaintiff’s claims ran until December 26, 2020. His Complaint was timely as it was docketed on December 23, 2020. Defendants, however, were not named therein; John Doe Defendants were named. “The naming of a John Doe defendant in a complaint does not stop the statute of limitations from running or toll the limitations period as to that defendant.” Garvin v. City of Philadelphia, 354 F.3d 215, 220 Gd Cir. 2003) (citing Talbert v. Kelly, 799 F.2d 62, 66 n.1 (3d Cir. 1986)). Accordingly, the claims against Defendants are time-barred unless Plaintiff can meet the requirements of Fed. R. Civ. P. 15(c), which allows amendments—in this case the amendment of the case caption to replace the Doe Defendants with the named

Defendants—to “relate back” to the filing date of the original complaint. See Singletary v. Pennsylvania Dep’t of Corr., 266 F.3d 186, 200-01 (3d Cir. 2001); Nelson v. Cnty. of Allegheny, 60 F.3d 1010, 1014-15 & n.6 (3d Cir.

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Wilson v. Garcia
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Rivera v. Rosaio, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-rosaio-ded-2023.