Rogstad v. Overguard

CourtDistrict Court, D. Idaho
DecidedAugust 23, 2019
Docket1:19-cv-00176
StatusUnknown

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

Bluebook
Rogstad v. Overguard, (D. Idaho 2019).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

JESSE RYAN ROGSTAD, Case No. 1:19-cv-00176-BLW Plaintiff, INITIAL REVIEW ORDER v. BY SCREENING JUDGE

LIEUTENANT OVERGAARD,

Defendant.

The Clerk of Court conditionally filed Plaintiff Jesse Ryan Rogstad’s Complaint as a result of Plaintiff’s status as an inmate and in forma pauperis request. The Court now reviews the Complaint to determine whether it or any of the claims contained therein should be summarily dismissed under 28 U.S.C. §§ 1915 and 1915A. Having reviewed the record, and otherwise being fully informed, the Court enters the following Order. 1. Screening Requirement The Court must review complaints filed by persons who cannot pay the filing fee and prisoners seeking relief against a governmental entity or an officer or employee of a governmental entity to determine whether summary dismissal is appropriate. The Court must dismiss a complaint or any portion thereof that states a frivolous or malicious claim, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) & 1915A(b). 2. Pleading Standard A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim

for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). To state a plausible civil rights claim under 42 U.S.C. § 1983, a plaintiff must

allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). 3. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction. He alleges that, in the spring of 2018, Lieutenant Overgaard came into his cell at 3:00 a.m.

and slid his mattress back by the bunk. Plaintiff told Overgaard to get out of his cell. Overgaard then pushed Plaintiff against the wall and bed, cracking his head and leaving a huge scar on the back of his head. (Dkt. 3, p. 2.) Plaintiff asserts that these acts violated his federal constitutional and state law rights. 4. Substantive Standards of Law

Unconstitutionally excessive force occurs when a government actor subjects a prisoner to gratuitous or disproportionate force that has no object but to inflict pain. Whitley v. Albers, 475 U.S. 312, 320-21 (1986). Under the Eighth Amendment, force is deemed legitimate in a custodial setting as long as it is applied “in a good faith effort to maintain or restore discipline [and not] maliciously and sadistically to cause harm.” Id. To determine if an application of force was applied maliciously and sadistically to

cause harm, a variety of factors are considered including: “the need for the application of force, the relationship between that need and the amount of force used, the threat reasonably perceived by the responsible officials, and any efforts made to temper the severity of a forceful response.” Hudson v. McMillian, 503 U.S. 1, 7-8 (1992); see also Whitley, 475 U.S. at 321; Harris v. Chapman, 97 F.3d 499, 505 (11th Cir. 1996). From

consideration of such factors, “inferences may be drawn as to whether the use of force could plausibly have been thought necessary, or instead evinced such wantonness with respect to the unjustified infliction of harm as is tantamount to a knowing willingness that it occur.” Whitley, 475 U.S. at 321. A state law claim of civil battery consists of an intentional, unpermitted contact

upon the person of another which is unlawful, harmful or offensive. White v. University of Idaho, 118 Idaho 400, 797 P.2d 108 (1990). The intent necessary for battery is the intent to commit the act, not the intent to cause harm. Id. 5. Discussion Though sparse, Plaintiff’s allegations state a federal and state law claim upon which

he can proceed. This Order does not guarantee that any of Plaintiff’s claims will be successful or that they have been presented in a procedurally proper manner. Rather, this Order merely finds that Plaintiff’s claims are plausible—meaning that these claims will not be summarily dismissed at this time but should proceed to the next stage of litigation. This Order is not intended to be a final or a comprehensive analysis of Plaintiff’s claims. 6. Request for Appointment of Counsel

Plaintiff also seeks appointment of counsel. Unlike criminal defendants, prisoners and indigents in civil actions have no constitutional right to counsel unless their physical liberty is at stake. Lassiter v. Dep’t of Soc. Servs., 452 U.S. 18, 25 (1981). Whether a court appoints counsel for indigent litigants is within the court’s discretion. Wilborn v. Escalderon, 789 F.2d 1328, 1331 (9th Cir. 1986).

In civil cases, counsel should be appointed only in “exceptional circumstances.” Id. To determine whether exceptional circumstances exist, the court should evaluate two factors: (1) the likelihood of success on the merits of the case, and (2) the ability of the plaintiff to articulate the claims pro se considering the complexity of legal issues involved. Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991). Neither factor is

dispositive, and both must be evaluated together. Id. Plaintiff’s Complaint, liberally construed, appears to state a claim upon which relief could be granted if the allegations are proven at trial. However, without more than the bare allegations of the Complaint, the Court does not have a sufficient basis upon which to assess the merits at this point in the proceeding. The legal issues in this matter

do not appear to be complex. Based on the foregoing, the Court will deny Plaintiff’s request for appointment of counsel without prejudice. If it seems appropriate later in this litigation, the Court will reconsider appointing counsel. A federal court has no authority to require attorneys to represent indigent litigants in civil cases under 28 U.S.C. § 1915

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

Related

Harris v. Chapman
97 F.3d 499 (Eleventh Circuit, 1996)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
White v. University of Idaho
797 P.2d 108 (Idaho Supreme Court, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
Rogstad v. Overguard, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rogstad-v-overguard-idd-2019.