Shunn v. Kootenai County

CourtDistrict Court, D. Idaho
DecidedNovember 8, 2022
Docket1:22-cv-00279
StatusUnknown

This text of Shunn v. Kootenai County (Shunn v. Kootenai County) 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
Shunn v. Kootenai County, (D. Idaho 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

FORREST GLENN SHUNN, Case No. 1:22-cv-00279-BLW Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

KOOTENAI COUNTY; KOOTENAI COUNTY P.A.; and JUDGE MITCHELL,

Defendants.

The Clerk of Court conditionally filed Plaintiff Forrest Glenn Shunn’s Complaint as a result of Plaintiff’s status as an inmate. The Court now reviews the Complaint to determine whether it should be summarily dismissed in whole or in part under 28 U.S.C. § 1915A. Having reviewed the record, and otherwise being fully informed, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed. 1. Pleading Standards and Screening Requirement 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). Under modern pleading standards, Rule 8 requires a complaint to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Iqbal/Twombly “facial plausibility”

standard is met when a complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “[D]etailed factual allegations” are

not required, but a plaintiff must offer “more than ... unadorned, the-defendant- unlawfully-harmed-me accusation[s].” Id. (internal quotation marks omitted). If the facts pleaded are “merely consistent with a defendant’s liability,” or if there is an “obvious alternative explanation” that would not result in liability, the

complaint has not stated a claim for relief that is plausible on its face. Id. at 678, 682 (internal quotation marks omitted). Bare allegations that amount to a mere restatement of the elements of a cause of action, without adequate factual support,

are not enough. The Prison Litigation Reform Act (“PLRA”)1 requires that the Court review complaints filed by prisoners seeking relief against a governmental entity or an officer or employee of a governmental entity, as well as complaints filed in forma

pauperis, to determine whether summary dismissal is appropriate. The Court must

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq. dismiss any claims that do not have adequate factual support or are frivolous or malicious. 28 U.S.C. § 1915A.

The Court also must dismiss claims 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. Id. These last two categories—together with claims that fall

outside a federal court’s narrow grant of jurisdiction—encompass those claims that might, or might not, have factual support but nevertheless are barred by a well- established legal rule. The Court liberally construes the pleadings to determine whether a case

should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable factual

and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000) (stating that Rule 12(b)(6) authority to dismiss claims was expanded by the PLRA,

giving courts power to dismiss deficient claims, sua sponte, before or after opportunity to amend). Moreover, even if a complaint meets the pleading requirements, dismissal under § 1915A is still appropriate if an affirmative defense

is an “obvious bar to securing relief on the face of the complaint.” Washington v. Los Angeles Cty. Sheriff’s Dep’t, 833 F.3d 1048, 1056 (9th Cir. 2016) (internal quotation marks omitted).

A court is not required to comb through a plaintiff’s exhibits or other filings to determine if the complaint states a plausible claim. Therefore, in its review under § 1915A, the Court has reviewed only the Complaint found at Docket No. 3,

not the affidavit attached to the Complaint. See General Order 342, In Re: Procedural Rules for Prisoner Civil Case Filings and for Prisoner E-Filing Program, § A(1)(b)-(c) (“No exhibits may be attached to a complaint or any type of amended complaint, except those showing exhaustion of administrative

remedies[,] [and] [n]o affidavits may be attached to a complaint or any type of amended complaint.”). 2. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction,

currently incarcerated at the Idaho Maximum Security Institution. Plaintiff alleges that his state court conviction is unconstitutional because, during the prosecution of that case, the Kootenai County prosecutor’s office “fraudulently added cases to

[his] convictions,” “demanded fees on fraud cases,” and threatened Plaintiff with incarceration. Compl., Dkt. 3, at 2. Plaintiff also claims that the judge in his criminal case “exaggerated on [the] record.” Plaintiff alleges that an unidentified governmental official “lied on [Plaintiff’s] drug possession [charge] as well,” apparently misidentifying the drug. Id. Plaintiff states that he “witnessed officers photoshop signatures.” Finally, Plaintiff alleges that unidentified individuals have

retaliated against him and that he has been raped, subjected to “extended time,” and threatened with changes in his custody level. Id. Plaintiff names as Defendants Kootenai County, the Kootenai County

prosecuting attorney, and the judge in his state court criminal case. Plaintiff seeks damages and injunctive relief. 3. Discussion Plaintiff has not alleged sufficient facts to proceed with the Complaint. The

Court will, however, grant Plaintiff 60 days to amend the Complaint. Any amended complaint should take into consideration the following. A. Section 1983 Claims Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To

state a plausible civil rights claim, 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).

Government officials generally are not liable for damages in their individual capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach Government official, his or her title notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does

not allow for recovery against an employer or principal simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045.

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Shunn v. Kootenai County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shunn-v-kootenai-county-idd-2022.