Smith v. Pierce County

CourtDistrict Court, W.D. Washington
DecidedFebruary 22, 2023
Docket3:23-cv-05061
StatusUnknown

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

Bluebook
Smith v. Pierce County, (W.D. Wash. 2023).

Opinion

1 2 3 4

5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 DALTON LOREN SMITH, CASE NO. 3:23-CV-5061-DGE-DWC 11 Plaintiff, ORDER DECLINING TO SERVE 12 v.

13 PIERCE COUNTY, et al., 14 Defendants.

15 16 Plaintiff Dalton Loren Smith, proceeding pro se and in forma pauperis, filed this civil 17 rights complaint under 42 U.S.C. § 1983. Having reviewed and screened Plaintiff’s complaint 18 under 28 U.S.C. § 1915A, the Court declines to serve Plaintiff’s complaint but provides Plaintiff 19 leave to file an amended pleading by March 24, 2023 to cure the deficiencies identified herein. 20 I. Background 21 Plaintiff, who is currently a convicted and sentenced state prisoner confined at the Pierce 22 County Jail, asserts claims arising out of his criminal proceedings in Pierce County superior 23 court. Dkt. 1 at 4–7. Plaintiff brings claims against Pierce County, as well as his defense counsel 24 and the prosecuting attorney. His complaint alleges claims of ineffective assistance of counsel 1 and a due process violation for failing to secure his presence at an omnibus hearing in superior 2 court. Id. As a result, he claims to have suffered emotional and mental stress and financial loss. 3 Id. at 7. As relief, Plaintiff seeks monetary damages. Id. at 9. 4 II. Discussion

5 Under the Prison Litigation Reform Act of 1995, the Court is required to screen 6 complaints brought by prisoners seeking relief against a governmental entity or officer or 7 employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss the 8 complaint, or any portion of the complaint, if the complaint: (1) is frivolous, malicious, or fails to 9 state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant 10 who is immune from such relief.” Id. at (b); 28 U.S.C. § 1915(e)(2); see Barren v. Harrington, 11 152 F.3d 1193 (9th Cir. 1998). 12 To state a claim for relief under 42 U.S.C. § 1983, a plaintiff must show: (1) he suffered a 13 violation of rights protected by the Constitution or created by federal statute, and (2) the 14 violation was proximately caused by a person acting under color of state law. See Crumpton v.

15 Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). The first step in a § 1983 claim is therefore to 16 identify the specific constitutional right allegedly infringed. Albright v. Oliver, 510 U.S. 266, 271 17 (1994). 18 To satisfy the second prong, a plaintiff must allege facts showing how individually 19 named defendants caused, or personally participated in causing, the harm alleged in the 20 complaint. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988); Arnold v. Int’l Bus. Machines 21 Corp., 637 F.2d 1350, 1355 (9th Cir. 1981). A person subjects another to a deprivation of a 22 constitutional right when committing an affirmative act, participating in another’s affirmative act, 23 or omitting to perform an act which is legally required. Johnson v. Duffy, 588 F.2d 740, 743 (9th

24 1 Cir. 1978). Sweeping conclusory allegations against an official are insufficient to state a claim for 2 relief. Leer, 844 F.2d at 633. Further, a § 1983 suit cannot be based on vicarious liability alone, but 3 must allege the defendant’s own conduct violated the plaintiff’s civil rights. City of Canton, Ohio 4 v. Harris, 489 U.S. 378, 385–90 (1989).

5 A. Municipal Liability 6 Plaintiff names Pierce County as a defendant in this case. A municipality qualifies as a 7 “person” who may be held liable under § 1983. See Monell v. Dep’t of Soc. Servs. of City of New 8 York, 436 U.S. 658, 690 (1978). 9 To set forth a claim against a municipality, a plaintiff must show the defendant’s 10 employees or agents acted through an official custom, pattern, or policy permitting deliberate 11 indifference to, or violating, the plaintiff’s civil rights, or that the entity ratified the unlawful 12 conduct. Monell, 436 U.S. at 690–91. A plaintiff must show (1) deprivation of a constitutional 13 right; (2) the municipality has a policy; (3) the policy amounts to deliberate indifference to a 14 plaintiff’s constitutional rights; and (4) the policy is the moving force behind the constitutional

15 violation. See Oviatt v. Pearce, 954 F.2d 1470, 1474 (9th Cir. 1992). 16 A municipality “cannot be held liable solely because it employs a tortfeasor—or, in other 17 words, a municipality cannot be held liable under § 1983 on a respondeat superior theory.” 18 Monell, 436 U.S. at 691 (emphasis in original). Similarly, mere negligence in training employees 19 cannot support municipal liability; instead, plaintiff must allege facts demonstrating the failure to 20 train amounts to deliberate indifference to the rights of those who deal with municipal 21 employees. City of Canton, 489 U.S. at 388–89. Finally, a single incident of unconstitutional 22 action is generally insufficient to state a claim for municipal liability. Benavidez v. Cnty. of San 23 Diego, 993 F.3d 1134, 1154 (9th Cir. 2021).

24 1 Plaintiff has not alleged facts supporting the County’s liability under Monell. He has not 2 identified a policy that is the moving force behind the constitutional violations alleged in the 3 complaint, and he has not alleged facts establishing that any such policy amounts to deliberate 4 indifference of his constitutional rights. If plaintiff wishes to pursue claims against Pierce

5 County, he must file an amended complaint that corrects these deficiencies. 6 B. Prosecutorial Immunity 7 Plaintiff names Sean Plunket, a Pierce County prosecuting attorney, as a defendant in this 8 case. Dkt. 1. Prosecutors are entitled to absolute immunity from liability for damages under § 9 1983. Imbler v. Pachtman, 424 U.S. 409, 427 (1976). Prosecutorial immunity protects a 10 prosecutor who “acts within his or her authority and in a quasi-judicial capacity.” Asheleman v. 11 Pope, 793 F.2d 1072, 1076 (9th Cir. 1986) (citing Imbler, 424 U.S. at 430-31). “Such immunity 12 applies even if it leaves ‘the genuinely wronged defendant without civil redress against a 13 prosecutor whose malicious or dishonest action deprives him of liberty.’” Id. (quoting Imbler, 14 424 U.S. at 427). As Defendant Plunket is a prosecutor and has immunity, Plaintiff must show

15 cause why this defendant should not be dismissed as a party in this case. 16 C. Heck Bar 17 Plaintiff’s claims directly challenge the validity of his conviction. Specifically, Plaintiff 18 claims: (1) he received ineffective assistance of counsel in his criminal proceedings (Dkt.

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

Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Demont R.D. Conner v. Theodore Sakai
15 F.3d 1463 (Ninth Circuit, 1994)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Ramirez v. Galaza
334 F.3d 850 (Ninth Circuit, 2003)
Johnson v. Duffy
588 F.2d 740 (Ninth Circuit, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
Smith v. Pierce County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-pierce-county-wawd-2023.