Smith v. Gwinnett County Board of Commissioners

CourtDistrict Court, N.D. Georgia
DecidedSeptember 30, 2024
Docket1:23-cv-02654
StatusUnknown

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

Bluebook
Smith v. Gwinnett County Board of Commissioners, (N.D. Ga. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

AUSTIN GARRICK SMITH, Plaintiff, Civil Action No. v. 1:23-cv-02654-SDG GWINNETT COUNTY BOARD OF COMMISSIONERS; and OFFICER J.L. BING, Defendants.

OPINION AND ORDER

This case is before the Court on Defendant Gwinnett County Board of Commissioners’ motion to dismiss [ECF 16]. After careful consideration of the briefing, the Court GRANTS the motion and DISMISSES this case. Plaintiff’s motion to extend his time to respond to the motion and amend his complaint [ECF 17] is GRANTED nunc pro tunc, and the motion to extend time to serve Officer Bing [ECF 21] is DENIED as moot. I. Background1 This case stems from Smith’s arrest in 2017.2 According to Smith, he was driving a friend on the evening of October 30, 2017, when he was pulled over by

1 Because the Court granted Smith’s motion to amend his pleading, the pleading filed at ECF 20 is the operative complaint. 2 ECF 20, at 5. Officer Bing.3 Officer Bing informed Smith that he pulled him over for speeding.4 During the interaction with Smith, Officer Bing noted that he smelled alcohol and

asked Smith to step out of the vehicle.5 Smith asked if he could submit to a breath alcohol test instead of field sobriety tests, and also asked if he could simply be given a citation because he had legal insurance that would cover his costs.6 Officer

Bing then allegedly arrested Smith for driving under the influence, handcuffed him, and placed him in the patrol car.7 Ultimately, Smith was charged with (a) DUI Less Safe - O.C.G.A. § 40-6-391(a)(l), (b) Speeding - O.C.G.A. § 40-6-181, (c) Reckless Driving - O.C.G.A. § 40-6-390, (d) No Valid Tag – O.C.G.A. § 40-2-

8(b)(2)(a), and (e) Failure to Display License - O.C.G.A. § 40-5-29.8 Smith alleges he was required to post “higher than normal bond due to the additional frivolous charges added by Officer Bing.”9 He was released that same evening.10

3 Id. 4 Id. 5 Id. 6 Id. at 5–6. 7 Id. at 6. 8 Id. at 7. 9 Id. 10 Id. Soon after, Smith inquired with Hyatt Legal Plans, with whom he claims he maintained legal insurance.11 Hyatt informed him that it would not provide

coverage because he was charged with DUI.12 Smith alleges that Officer Bing knew that legal insurance does not cover DUI charges and added the DUI charge so that Smith would not be eligible for coverage.13

Smith “appeared in State Court numerous times over the next few years” while dealing with the charges.14 Of particular concern to Smith is his alleged violation of O.C.G.A. § 40-2-8(b)(2)(A), which according to him, “has been exploited to punish tag violations with the full breadth of a misdemeanor. This

exploitation by multiple distinct roles involved conspires to deprive Constitutional rights afforded by due process and unusual punishment through established practice and unwritten policy.”15 Regardless, on February 10, 2020,

“dismissal was initiated by the Solicitor for all citations except the speeding citation issued by Officer Bing during a non-negotiated plea.”16

11 Id. at 8. 12 Id. 13 Id. 14 Id. 15 Id. 16 Id. Smith initiated this case against Officer Bing and Gwinnett County on June 12, 2023, nearly six years after the October 2017 events and over three years after

all charges were dropped.17 Smith brings claims under 42 U.S.C. § 1983, alleging violations of the Fourth, Eighth, and Fourteenth Amendments. In his amended complaint, Smith attempts to add a § 1981 claim for interference with contract.18

Prior to Smith amending his complaint, Gwinnett County moved to dismiss.19 Smith then responded to the motion,20 amended his complaint,21 and moved for an extension of time to perfect service on Officer Bing.22 Gwinnett County replied, indicating that the amended pleading did not overcome the

deficiencies identified in its motion and thus, argues that its motion should still be granted. II. Legal Standard To withstand a Rule 12(b)(6) motion to dismiss, a complaint must “contain

sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Am. Dental Ass’n v. Cigna Corp., 605 F.3d 1283, 1289 (11th Cir. 2010)

17 ECF 1. 18 ECF 20. 19 ECF 16. 20 ECF 18. 21 ECF 20. 22 ECF 21. (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A complaint is plausible on its face when the plaintiff pleads the factual content necessary for the

court to draw the reasonable inference that the defendant is liable for the conduct alleged. Id. (citing Twombly, 550 U.S. at 556). At the motion to dismiss stage, “all well-pleaded facts are accepted as true,

and the reasonable inferences therefrom are construed in the light most favorable to the plaintiff.” FindWhat Inv’r Grp. v. FindWhat.com, 658 F.3d 1282, 1296 (11th Cir. 2011) (quoting Garfield v. NDC Health Corp., 466 F.3d 1255, 1261 (11th Cir. 2006)). However, this principle does not apply to legal conclusions set forth in the

complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When a plaintiff chooses to proceed pro se, his or her complaint is “held to less stringent standards than formal pleadings drafted by lawyers” and must be

“liberally construed.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citation and quotation omitted); see also Boxer X v. Harris, 437 F.3d 1107, 1110 (11th Cir. 2006). However, the Court “need not accept as true legal conclusions or unwarranted

factual inferences” contained in complaints filed by pro se litigants. Montgomery v. Huntington Bank, 346 F.3d 693, 698 (6th Cir. 2006) (quotation and citation omitted). And furthermore, pro se plaintiffs are required to comply with threshold requirements of the Federal Rules of Civil Procedure. Trawinski v. United Techs.,

313 F.3d 1295, 1299 (11th Cir. 2002). III. Discussion Gwinnett County argues that Smith’s claims should be dismissed because

they are time barred, that the claims against Officer Bing must be dismissed for failure to properly serve him, and because Smith has failed to otherwise state a claim based on municipal and qualified immunity. The Court agrees that Smith’s claims are time-barred and thus, need not address the additional arguments.

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Smith v. Gwinnett County Board of Commissioners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-gwinnett-county-board-of-commissioners-gand-2024.