SMITH v. CLEVELAND

District Court, M.D. Georgia·Decided March 17, 2025·No. 3:24-cv-00104·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ATHENS DIVISION

ROBERT LEE SMITH, : : Plaintiff, : : V. : : NO. 3:24-cv-00104-CDL-CHW MIKE CLEVELAND, et al., : : Defendants. : : _________________________________:

AMENDED ORDER1 Plaintiff Robert Lee Smith, who is currently in the Hart County Jail in Hartwell, Georgia, filed a civil rights complaint under 42 U.S.C. § 1983. ECF No. 1. Plaintiff also filed a motion for leave to proceed in forma pauperis. ECF No. 6. Thereafter, Plaintiff was granted leave to proceed in forma pauperis and ordered to pay an initial partial filing fee. ECF No. 7. Plaintiff has now paid the initial partial filing fee, and thus, his complaint is ripe for preliminary review. On that review, Plaintiff will be permitted to proceed for further factual development on his claim for excessive force against Defendants Sheriff Mike Cleveland, Deputy Stephen Williams, Deputy Kenneth Dutton, Deputy Joshua Fowler, Deputy Jared Banister, and Deputy Tyler Henley.

1On March 11, 2025, this Court entered an order which inadvertently referred to Mike Cleveland as a Georgia State Patrol Officer. ECF No. 8 at 3. This amended order identifies Mike Cleveland as being the Hart County Sheriff during the events at issue in this case. This order has also been amended to reflect Plaintiff’s allegation that an unnamed Georgia State Patrol Officer, rather than a deputy, ran Plaintiff into a wall to end a high-speed police chase. PRELIMINARY REVIEW OF PLAINTIFF’S COMPLAINT I. Standard of Review

The PLRA obligates the district courts to conduct a preliminary screening of every complaint filed by a prisoner who seeks redress from a government entity, official, or employee. See 28 U.S.C. § 1915A(a). Screening is also required under 28 U.S.C. § 1915(e) when the plaintiff is proceeding in forma pauperis. Both statutes apply in this case, and the standard of review is the same. When conducting preliminary screening, the Court generally must accept factual allegations in the complaint as true. Boxer X v.

Harris, 437 F.3d 1107, 1110 (11th Cir. 2006), abrogated in part on other grounds by Wilkins v. Gaddy, 559 U.S. 34 (2010); Hughes v. Lott, 350 F.3d 1157, 1159-60 (11th Cir. 2003). Pro se pleadings, like the one in this case, are “‘held to a less stringent standard than pleadings drafted by attorneys and will, therefore, be liberally construed.’” Hughes, 350 F.3d at 1160 (citation omitted). Still, the Court must dismiss a prisoner complaint if

it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. §1915A(b). A claim is frivolous if it “‘lacks an arguable basis either in law or in fact.’” Miller v. Donald, 541 F.3d 1091, 1100 (11th Cir. 2008) (citation omitted). The Court may

dismiss claims that are based on “‘indisputably meritless legal’” theories and “‘claims whose factual contentions are clearly baseless.’” Id. (citation omitted). A complaint fails to state a claim if it does not include “sufficient factual matter, accepted as true, to ‘state a 2 claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The factual allegations

in a complaint “must be enough to raise a right to relief above the speculative level” and cannot “‘merely create[] a suspicion [of] a legally cognizable right of action.’” Twombly, 550 U.S. at 555 (citation omitted). In other words, the complaint must allege enough facts “to raise a reasonable expectation that discovery will reveal evidence” supporting a claim. Id. at 556. “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678.

To state a claim for relief under § 1983, a plaintiff must allege that (1) an act or omission deprived him of a right, privilege, or immunity secured by the Constitution or a statute of the United States; and (2) the act or omission was committed by a person acting under color of state law. Hale v. Tallapoosa Cnty., 50 F.3d 1579, 1582 (11th Cir. 1995). If a litigant cannot satisfy these requirements or fails to provide factual allegations in

support of his claim or claims, the complaint is subject to dismissal. See Chappell v. Rich, 340 F.3d 1279, 1282-84 (11th Cir. 2003). II. Factual Allegations In his complaint, Plaintiff asserts that he was involved in a police chase in Lavonia, Georgia, on October 24, 2023. ECF No. 1 at 5. The chase ended after Hart County

Sheriff Mike Cleveland authorized an unnamed Georgia State Patrol officer to force Plaintiff off the road into a concrete wall. Id. Thereafter, Plaintiff surrendered and was put in handcuffs. Id. While Plaintiff was in handcuffs, Deputies Stephen Williams, 3 Kenneth Dutton, Joshua Fowler, Jared Banister, and Tyler Henley punched Plaintiff multiple times and kicked him in the face while asking Plaintiff why he did not stop. Id.

III. Plaintiff’s Claim Plaintiff’s allegations raise a potential claim for excessive force against the defendants. “The Fourth Amendment’s freedom from unreasonable searches and seizures encompasses the plain right to be free from the use of excessive force in the course of an arrest.” Lee v. Ferraro, 284 F.3d 1188, 1197 (11th Cir. 2002). Although the right to use some degree of force comes with the right to make an arrest, the question is whether the

force used was reasonable, which is judged on a case-by-case basis. Brown v. City of Huntsville, Ala., 608 F.3d 724, 737-38 (11th Cir. 2010). Here, Plaintiff asserts that, in order to end the police chase, Sheriff Mike Cleveland authorized a Georgia State Patrol officer to force Plaintiff off the road into a concrete wall.2 Although it is possible that this use of force was reasonable, at this stage of the proceeding,

the Court will accept Plaintiff’s allegations as true and construe them in his favor. Given the potential danger of forcing a car into a concrete wall, it appears possible that the use of force could have been unreasonable, and thus, Plaintiff may proceed for further factual development on his claim that Sheriff Cleveland authorized the use of excessive force to end the police chase.

2Plaintiff has not alleged any facts to show that any of the named deputies were involved in the maneuver that forced him off the road. Thus, only Sheriff Cleveland is discussed with regard to this portion of Plaintiff’s excessive force claim. 4 Additionally, Plaintiff contends that, once he had surrendered and was put into handcuffs, all of the named deputies punched and kicked Plaintiff. Accepting this

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Related

Wilkins v. Gaddy
559 U.S. 34 (Supreme Court, 2010)
Kim D. Lee v. Luis Ferraro
284 F.3d 1188 (Eleventh Circuit, 2002)
Ned Hughes v. Charles Lott
350 F.3d 1157 (Eleventh Circuit, 2003)
Miller v. Donald
541 F.3d 1091 (Eleventh Circuit, 2008)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Brown v. City of Huntsville, Ala.
608 F.3d 724 (Eleventh Circuit, 2010)
Hale v. Tallapoosa County
50 F.3d 1579 (Eleventh Circuit, 1995)
Chappell v. Rich
340 F.3d 1279 (Eleventh Circuit, 2003)
Boxer X v. Harris
437 F.3d 1107 (Eleventh Circuit, 2006)