Thomas Warren v. John Jayne, Boise Police Department

CourtDistrict Court, D. Idaho
DecidedOctober 15, 2025
Docket1:23-cv-00319
StatusUnknown

This text of Thomas Warren v. John Jayne, Boise Police Department (Thomas Warren v. John Jayne, Boise Police Department) 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
Thomas Warren v. John Jayne, Boise Police Department, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

THOMAS WARREN,

Plaintiff, Case No. 1:23-cv-00319-DKG

vs. THIRD REVIEW ORDER

JOHN JAYNE, Boise Police Department,

Defendant.

This case was reassigned to this Court as a result of all parties’ consent to the jurisdiction of a United States Magistrate Judge to enter final orders in this case. Dkt. 24. The operative pleading in this case is an Amended Complaint filed on December 6, 2023. Dkt. 9. Earlier in this prisoner civil rights matter of Plaintiff Thomas Warren (Plaintiff), United States District Judge B. Lynn Winmill ordered Defendant Boise police officer John Jayne, to prepare and submit a Martinez Report to provide additional facts regarding Plaintiff’s welfare check and arrest that are the subject of his claims. See Martinez v. Aaron, 570 F.2d 317 (10th Cir. 1978). Defendants have filed their report. Dkt. 19. Though optional, Plaintiff has filed no substantive response or objection to the Martinez Report and its attachments, but has filed several requests to know the status of the case. REVIEW OF AMENDED COMPLAINT AND MARTINEZ REPORT

1. Standard of Law for Screening Prisoner Pleadings Federal Rule of Civil Procedure 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 Prison Litigation Reform Act (PLRA)1 requires the Court to screen all pro se prisoner and pauper complaints to determine whether they have stated a

claim upon which relief can be granted before such complaints are served on the defendants. 28 U.S.C. §§ 1915 & 1915A. The Court must dismiss any claims that are frivolous or malicious, 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. 28 U.S.C. § 1915(e)(2)(B). The Court liberally construes a plaintiff’s pleadings to determine whether

the case should be dismissed for lack of a cognizable legal theory or failure to plead sufficient facts under the Iqbal/Twombly standard. The Court also has authority to seek additional information from the parties to assess Plaintiff’s claims during the screening process by requiring an amended complaint and/or a Martinez report. In Martinez, rather than dismissing the complaint or sending it out for service and

an answer, the district court ordered prison officials to conduct an investigation of the incident to include an interrogation of those concerned. The transcripts of the interrogations and an explanation by the officials were to be provided to the court to

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq. enable it to decide the jurisdictional issues and make a screening determination under 28 U.S.C. § 1915(a). Id. at 319. The United States Court of Appeals for the Ninth Circuit approved the use of Martinez reports in In re Arizona, 528 F.3d 652, 659 (9th Cir. 2008),

concluding that, “[a]s a permissible option within its broad discretion, a district court in an appropriate case can issue a Martinez-style order that is reasonably tailored to the pretrial needs of the district court to assess the case.” Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute, which is an implementing statute authorizing private causes of action under the Amendments to the

United States Constitution. To state a claim under § 1983, 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). 2. Factual Allegations

Plaintiff admits that, on June 30, 2022, he and his wife had an argument about his alcoholism and he had sent “drunken texts” to his wife. Plaintiff’s wife had left the house, and Plaintiff was sleeping when officers arrived for a “welfare check.” See original Complaint, Dkt. 3. Four Boise Police officers, including Defendant John Jayne, came to Plaintiff’s house after receiving a request from Plaintiff’s wife to perform a welfare check

on Plaintiff. Plaintiff alleges that Officer Jayne arrested him without probable cause or a warrant. Plaintiff also alleges that Officer Jayne unnecessarily applied a chokehold to Plaintiff’s neck, causing bruises, cuts, and abrasions. Finally, Officer Jayne allegedly unnecessarily placed Plaintiff in an involuntary medical hold in the Intermountain Hospital for a period of 144 hours. Plaintiff seeks monetary damages of $50,000. See Dkt. 9.

3. Arrest without Probable Cause or Warrant Plaintiff alleges that Officer Jayne arrested him without probable cause or a warrant. Involuntary confinement or civil commitment is a significant deprivation of liberty that requires due process protections. See Addington v. Texas, 441 U.S. 418, 425 (1979). Cf. Maag v. Wessler, 960 F.2d 773, 775–76 (9th Cir. 1992) (per curiam).

Warrantless searches and seizures are presumed to be unreasonable and therefore violate the Fourth Amendment. State v. Weaver, 127 Idaho 288, 290, 900 P.2d 196, 198 (1995). A state actor may overcome this presumption by demonstrating that a warrantless search either fell within a well-recognized exception to the warrant requirement or was otherwise reasonable under the circumstances. Id.

Where a crime is not initially at issue, a search or detention may be reasonable under an officer’s “community caretaking” function. State v. Cutler, 143 Idaho 297, 302, 141 P.3d 1166, 1171 (Idaho Ct. App. 2006). The community caretaking function arises from the duty of police officers to help citizens in need of assistance and is totally divorced from the detection, investigation, or acquisition of evidence relating to the

violation of a criminal statute. Id., 143 Idaho at 302, 141 P.3d at 1171; State v. Maddox, 137 Idaho 821, 824, 54 P.3d 464, 467 (Idaho Ct. App. 2002); State v. Page, 140 Idaho 841, 843, 103 P.3d 454, 457 (Idaho 2004). The “community caretaking function” permits an officer to detain a person when there is a present need for assistance, but does not permit unlimited searching of the detainee. State v. Adams, No. 50841, 2025 WL 2301197, at *4 (Idaho Aug. 11, 2025).

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Michigan v. Fisher
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422 U.S. 563 (Supreme Court, 1975)
Addington v. Texas
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Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Hudson v. McMillian
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Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Ashcroft v. Iqbal
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Ahern v. O'Donnell
109 F.3d 809 (First Circuit, 1997)
Roberts v. Spielman
643 F.3d 899 (Eleventh Circuit, 2011)
Martinez v. Aaron
570 F.2d 317 (Tenth Circuit, 1978)
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658 F.3d 897 (Ninth Circuit, 2011)
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555 F.3d 324 (Fourth Circuit, 2009)
State v. Weaver
900 P.2d 196 (Idaho Supreme Court, 1995)
State v. Wixom
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State v. Godwin
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Matter of Clayton
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