Taylor v. Prince George's County, Maryland

377 F. Supp. 1004, 1974 U.S. Dist. LEXIS 7793
CourtDistrict Court, D. Maryland
DecidedJuly 1, 1974
DocketCiv. 73-1113-HM
StatusPublished
Cited by4 cases

This text of 377 F. Supp. 1004 (Taylor v. Prince George's County, Maryland) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Taylor v. Prince George's County, Maryland, 377 F. Supp. 1004, 1974 U.S. Dist. LEXIS 7793 (D. Md. 1974).

Opinion

HERBERT F. MURRAY, District Judge.

Charles Taylor, a minor resident of the District of Columbia, brought this action on November 12, 1973 through his mother, Sarah Taylor, to recover damages against Jay Harrington, an officer of the Prince George’s County, Maryland Police Department [hereinafter the County] for injuries received during an attack by a police dog under Harrington’s supervision. 1 The theoretical bases for this suit are the Civil Rights Act of 1871, 42 U.S.C. § 1983, and the Maryland common law governing the torts of negligence and assault and battery. Jurisdiction over the federal cause of action rests on 28 U.S.C. § 1343(4), whereas the state law claims are grounded on either the diverse citizenship of the parties or the doctrine of pendant jurisdiction. The amount of damages sought against each defendant exceeds the statutory prerequisite of $10,000 and venue is properly laid in this district pursuant to 28 U.S.C. § 1391 because the incident triggering this litigation occurred in Maryland. Harrington has answered the complaint with a general denial of the alleged wrongdoing and raised, as an affirmative defense, the doctrine of sovereign immunity which purportedly shields the officers of a Maryland agency from tort liability unless they consent to the suit. The County subsequently moved to dismiss under Rule 12(b) of the Federal Rules of Civil Procedure for failure of the plaintiffs to state a claim upon which relief can be granted. More precisely, it argues that a county is not a “person” within the meaning of 42 U.S.C. § 1983 and is not subject to an action for damages under that section. Second, the County asserts that the officer was acting as an agent of the state of Maryland when he arrested Taylor and that principals alone are liable for the torts of their agents. Finally, it contends that Article 57 of the Annotated Code of Maryland precludes suit against Maryland counties unless they receive notice within one hundred and eighty days of the injury and that this prerequisite is not alleged in the complaint.

In his response to this motion, the plaintiff concedes that the County is not subject to a claim for damages under 42 U.S.C. § 1983 and consents to the dismissal of that cause of action. See Monroe v. Pape, 365 U.S. 167, 81 S.Ct. 473, 5 L.Ed.2d 492 (1961). Taylor insists, however, that notice of the incident was received by the Prince George’s County Council on July 30, 1973, through a registered letter and has submitted an affidavit from his counsel, a copy of the letter describing the purported assault, and a return receipt to support this assertion. From these documents, it is apparent that Taylor informed the County of his injuries within *1006 the meaning of Article 57 of the Annotated Code of Maryland and that this notification is sufficient to avoid dismissal of his common law tort claims on this ground.

Nevertheless, resolution of these preliminary questions underlying the motion to dismiss still leaves the Court with two further issues which require more extended consideration. First, the Court is compelled to raise sua sponte the propriety of its subject matter jurisdiction over an allegation of tortious conduct under state law where one of the diverse parties is a municipal entity. Second, there is a dispute between all parties concerning the legal relationship of Harrington to the County and the state of Maryland which is central to the defense that police officers are agents of the state and that the municipalities are, therefore, freed from liability for their employee’s misconduct.

I.

Since dismissal of the federal question cause of action against the County eliminates the juridical basis on which the Court could determine the state law claims under the doctrine of pendant jurisdiction, the appropriate inquiry becomes whether a Maryland County is a “citizen” within the meaning of 28 U.S.C. § 1332(a)(1). 2 United Mine Workers v. Gibbs, 383 U.S. 715, 86 S.Ct. 1130, 16 L.Ed.2d 218 (1966); Shuman v. Sherman, 356 F.Supp. 911 (D.Md.1973). At the outset, it is settled law that neither a state nor its instrumentalities are citizens for the purpose of establishing federal diversity jurisdiction. Postal Telegraph Cable Co. v. Alabama, 155 U.S. 482, 15 S.Ct. 192, 39 L.Ed. 231 (1894); Fifty Associates v. Prudential Insurance Co. of America, 446 F.2d 1187, 1191 (9th Cir. 1970); Krisel v. Duran, 386 F.2d 179 (2nd Cir. 1967). The corollary to this premise recognizes that a “political subdivision of a State, unless it is simply the arm or alter ego of the State, is a citizen of the State for diversity purposes” and that the status of a county as an independent legal entity is determined by examining state law. Moor v. County of Alameda, 411 U.S. 693, 93 S.Ct. 1785, 36 L.Ed.2d 596 (1973); Illinois v. City of Milwaukee, 406 U.S. 91, 92 S.Ct. 1385, 31 L.Ed.2d 712 (1972); Lincoln County v. Luning, 133 U.S. 529, 10 S.Ct. 363, 33 L.Ed. 766 (1890).

While decisions subsequent to Moor have held without extensive analysis that counties are presumptively citizens of the state of their location Hampton v. City of Chicago, Cook County, Illinois, 484 F.2d 602, 610 (7th Cir. 1973); Pyramid Corp. v. DeSoto County Board of Supervisors, 366 F.Supp. 1299, 1301 (N.D.D.Miss.1973), it is apparent from Justice Marshall’s opinion that only an autonomous legal entity enjoys the status of state citizenship under the diversity statute. Moreover, those factors evidencing the independence of Alameda County were carefully defined:

Most notably, under California law a county is given “corporate powers” and is designated a “body corporate and politic.” In this capacity, a county may sue and be sued, and, significantly for the purposes of this suit, it is-deemed . . .a “local public entity” in contrast to the State and state agencies. In addition . . .

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Related

Gray-Hopkins v. Prince George's County, Maryland
163 F. Supp. 2d 571 (D. Maryland, 2001)
Daughtry v. Arlington County, Va.
490 F. Supp. 307 (District of Columbia, 1980)
Bradshaw v. Prince George's County
396 A.2d 255 (Court of Appeals of Maryland, 1979)
Schoonfield v. Mayor and City Council of Baltimore
399 F. Supp. 1068 (D. Maryland, 1975)

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Bluebook (online)
377 F. Supp. 1004, 1974 U.S. Dist. LEXIS 7793, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-prince-georges-county-maryland-mdd-1974.