Rodriguez v. Wagoner County Board of County Commissioners

CourtDistrict Court, E.D. Oklahoma
DecidedMarch 3, 2022
Docket6:20-cv-00037
StatusUnknown

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

Bluebook
Rodriguez v. Wagoner County Board of County Commissioners, (E.D. Okla. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

ELIZABETH MARIE RODRIGUEZ, ) ) ) ) Plaintiff, ) ) v. ) Case No. CIV-20-037-RAW ) BOARD OF COUNTY ) COMMISSIONERS OF THE ) COUNTY OF WAGONER, et al., ) ) ) ) ) ) Defendants. ) ORDER Before the court is the motion of defendant Shanne Sampson1 for summary judgment. This lawsuit commenced in the District Court for Wagoner County. The case was removed to this court by defendants. Plaintiff brings claims pursuant to 42 U.S.C. §1983 for the alleged deprivation of the civil rights of a pretrial detainee. Specifically, the First Amended Complaint alleged (1) excessive force [as to all defendants], (2) medical indifference [as to movant and Sheriff Elliott], (3) failure to intervene [as to all defendants] and (4) an official 1In the First Amended Complaint (#9), the defendant’s first name is spelled Shane. In the pending motion, it is spelled Shanne. See also #63-8. liability claim [as to Wagoner County].2 Movant was the jail administrator during the litigated events.

Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Rule 56(a) F.R.Cv.P. A dispute is genuine when the evidence is such that a reasonable jury could return a verdict for the nonmoving party; a fact is material when it might affect the outcome of the suit under governing law. See Foster v. Mountain Coal Co., 830 F.3d 1178,

1187 (10th Cir.2016). The court must view all evidence and draw reasonable inferences therefrom in the light most favorable to the nonmoving party. Spring Creek Expl. & Prod. Co. v. Hess Bakken Inv., II, LLC, 887 F.3d 1003, 1026 (10th Cir.2018). The court’s duty is not to weigh the evidence and determine the truth of the matter but to determine whether

there is a genuine issue for trial. See Ohlsen v. United States, 998 F.3d 1143, 1153 (10th Cir.2021). Where, however, a §1983 defendant raises qualified immunity as a defense, the standard for reviewing a motion for summary judgment is different. A §1983 defendant’s

assertion of qualified immunity is an affirmative defense that creates a presumption that the defendant is immune from suit. See Truman v. Orem City, 1 F.4th 1227, 1235 (10th

2Plaintiff also contends she has alleged a claim for violation of substantive due process. This dispute (as to the claim’s existence and its merits) will be addressed in due course. 2 Cir.2021). When the defense is raised, as movant has here3, the burden shifts to the plaintiff to show that (1) the defendant violated a constitutional right and (2) the constitutional right was clearly established. Halley v. Huckaby, 902 F.3d 1136, 1144 (10th Cir.2018).4 If, and

only if, the plaintiff meets this two-part test does a defendant then bear the traditional burden of the movant for summary judgment. Id. In determining whether the plaintiff meets this burden, the court ordinarily accepts the plaintiff’s version of the facts – that is, the facts alleged. Id. At summary judgment,

however, because the court is beyond the pleading phase of the litigation, the plaintiff’s version of the facts must find support in the record. Id. Thus, if the nonmoving party’s version of the facts is blatantly contradicted by the record, so that no reasonable jury could believe it, the court should not adopt that version of the facts. Id.

To show defendant is not entitled to qualified immunity, a plaintiff must show that (1) the facts that the district court ruled a reasonable jury could find would suffice to show a legal violation, and (2) the law was clearly established at the time of the alleged violation. Id. A constitutional right is clearly established if it is sufficiently clear that every reasonable

3A qualified immunity defense is only available to parties sued in their individual capacities. Beedle v. Wilson, 422 F.3d 1059, 1069 (10th Cir.2005). Movant’s motion for dismissal in his official capacity was previously granted (#31). 4This court may exercise its sound discretion in deciding which of the two prongs should be addressed first. See Frasier v. Evans, 992 F.3d 1003, 1033 (10th Cir.2021). If the plaintiff fails to establish either prong of the two-pronged qualified- immunity standard, the defendant prevails on the defense. A.M. v. Holmes, 830 F.3d 1123, 1134-35 (10th Cir.2016). 3 official would have understood that what he is doing violates that right. Id. A Supreme Court or Tenth Circuit decision on point or the weight of authority from other courts can

clearly establish a right. Id. The question is not whether a “broad general proposition” was clearly established, but whether the violative nature of particular conduct was clearly established. Id. Movant has asserted qualified immunity as to the excessive force claim (#63 at pages 21-23 of 33 in CM/ECF pagination) and as to the failure to intervene claim (Id. at page 31

of 33). The Fourteenth Amendment governs excessive force claims by pretrial detainees. Nosewicz v. Janosko, 857 Fed.Appx. 465, 468 (10th Cir.2021). A defendant violates the Fourteenth Amendment by purposely or knowingly using force against a pretrial detainee that

is “objectively unreasonable.” Id. See Kingsley v. Hendrickson, 576 U.S. 389, 397 (2015). Objective reasonableness turns on the facts and circumstances of each particular case. Id. The court (or a jury) makes this determination from the perspective of a reasonable officer on the scene, including what the officer knew at the time, not with the 20/20 vision of

hindsight. Id. Among the non-exclusive factors bearing on the question are the relationship between the need for the use of force and the amount of force used; the extent of the plaintiff’s injury; any effort made by the officer to temper or to limit the amount of force; the severity of the security problem at issue; the threat reasonably perceived by the officer; and whether the plaintiff was actively resisting. Id. at 469.

4 The factual basis for the court’s decision is as follows.5 Plaintiff was a pretrial detainee in the Wagoner County Jail from March 27, 2017 until conviction on October 22,

2018. She was then transferred to another facility on October 24, 2018. Plaintiff had episodes in jail in which she attempted to kill herself or otherwise raised concerns for self- harm. She was also involved in numerous altercations with other inmates or with jailers. Plaintiff admits that, as of June 4, 2018, she had a long history of not following orders from the jail staff. On the morning of June 4, 2018, plaintiff was involved in a fight with another

female inmate in the jail. As a result, plaintiff was visited in her cell by Judy Elliott, Sheriff Elliott and other jail staff. She was told she would be placed on “lockdown.” Plaintiff told jail staff she refused the order. After she had returned from the medical staff for an unrelated condition,

defendants Riggs (Undersheriff) and Sampson (present movant) came to her cell and again told her she would be placed on lockdown. Plaintiff stated she would kill herself if she had to lockdown. Plaintiff asserts she then got into an altercation with Riggs and Sampson. She asserts Sampson touched her back and Riggs put her into a bear hug from behind. She

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Sealock v. State Of Colorado
218 F.3d 1205 (Tenth Circuit, 2000)
Hyde Park Co. v. Santa Fe City Council
226 F.3d 1207 (Tenth Circuit, 2000)
Beedle v. Wilson
422 F.3d 1059 (Tenth Circuit, 2005)
Fogarty v. Gallegos
523 F.3d 1147 (Tenth Circuit, 2008)
Vondrak v. City of Las Cruces
535 F.3d 1198 (Tenth Circuit, 2008)
Donald Frohmader v. Deputy D. Wayne
958 F.2d 1024 (Tenth Circuit, 1992)
Meek v. Jordan
534 F. App'x 762 (Tenth Circuit, 2013)
Al-Turki v. Robinson
762 F.3d 1188 (Tenth Circuit, 2014)
Jones v. Norton
809 F.3d 564 (Tenth Circuit, 2015)
A.M. Ex Rel. F.M. v. Holmes
830 F.3d 1123 (Tenth Circuit, 2016)
Foster v. Mountain Coal Company
830 F.3d 1178 (Tenth Circuit, 2016)
Halley v. Huckaby
902 F.3d 1136 (Tenth Circuit, 2018)
City of Escondido v. Emmons
586 U.S. 38 (Supreme Court, 2019)
Lindsey v. Hyler
918 F.3d 1109 (Tenth Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Rodriguez v. Wagoner County Board of County Commissioners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-v-wagoner-county-board-of-county-commissioners-oked-2022.