Trista Tramposch di Genova v. Olivia Russo, et al.

CourtDistrict Court, D. Arizona
DecidedJanuary 14, 2026
Docket4:25-cv-00598
StatusUnknown

This text of Trista Tramposch di Genova v. Olivia Russo, et al. (Trista Tramposch di Genova v. Olivia Russo, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trista Tramposch di Genova v. Olivia Russo, et al., (D. Ariz. 2026).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Trista Tramposch di Genova, No. CV-25-00598-TUC-JCH

10 Plaintiff, ORDER

11 v.

12 Olivia Russo, et al.,

13 Defendants. 14 15 Before the Court is pro se Plaintiff Trista Tramposch di Genova’s Complaint 16 alleging violations of 42 U.S.C. § 1983 and state law by Defendants Dr. Olivia Russo 17 (“Dr. Russo”) and VCA Animal Hospital, Tucson (“VCA”) (“Complaint”) (Doc. 1). Also 18 before the Court is Plaintiff’s Application to Proceed In District Court Without Prepaying 19 Fees or Costs (“Motion”) (Doc. 2). The Court will grant the Motion and dismiss the 20 Complaint and this case. 21 I. Application to Proceed In District Court Without Prepaying Fees and Costs 22 The Motion indicates Plaintiff has insufficient funds to pay the filing fee. Good 23 cause appearing, the Court will grant the Motion. 24 II. Statutory Screening of In Forma Pauperis Complaints 25 Pursuant to 28 U.S.C. § 1915(e)(2), in a case in which a plaintiff has been granted 26 in forma pauperis status, the Court shall dismiss the case “if the court determines that . . . 27 (B) the action . . . (i) is frivolous or malicious; (ii) fails to state a claim on which relief may 28 be granted; or (iii) seeks monetary relief against a defendant who is immune from such 1 relief.”1 2 A pleading must contain a “short and plain statement of the claim showing that the 3 pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). While Rule 8 does not demand detailed 4 factual allegations, “it demands more than an unadorned, the-defendant-unlawfully- 5 harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “[A] complaint must 6 contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible 7 on its face.’” Id. (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A 8 claim is plausible “when the plaintiff pleads factual content that allows the court to draw 9 the reasonable inference that the defendant is liable for the misconduct alleged.” Id. 10 Still, the Court must “construe pro se filings liberally.” Hebbe v. Pliler, 627 F.3d 11 338, 342 (9th Cir. 2010). A “complaint [filed by a pro se litigant] ‘must be held to less 12 stringent standards than formal pleadings drafted by lawyers.’” Id. (quoting Erickson v. 13 Pardus, 551 U.S. 89, 94 (2007) (per curiam)). If the Court determines a complaint could 14 be cured by the allegation of additional facts, a pro se litigant is entitled to an opportunity 15 to amend that complaint before dismissal of the action. See Lopez v. Smith, 203 F.3d 1122, 16 1127–29 (9th Cir. 2000) (en banc). 17 III. Complaint 18 Plaintiff alleges the following facts in her Complaint: 19 On August 24, 2023, Plaintiff entrusted a third party, Zoe Skinner, to take her 20 service dog, Hank/Dr. Hank, to the vet. Doc. 1 at 2. After having Hank for about an hour, 21 Ms. Skinner took him to VCA. Id. Though Plaintiff told Ms. Skinner “that Hank was to 22 receive antibiotics and post-surgical care . . . and requested a second opinion,” Ms. Skinner 23 represented to Dr. Russo that she was Hank’s owner and said Hank should be euthanized. 24 Id. Plaintiff’s name, phone number, and address were listed on Hank’s microchip and 25 veterinary records. Id. Dr. Russo was required by Arizona state law to make reasonable 26 efforts to contact Plaintiff before euthanizing Hank, but she did not. Id. Relying solely on 27 Ms. Skinner’s representations, Dr. Russo euthanized Hank. Id.

28 1 The Court also has an independent obligation to dismiss a case if the Court determines it lacks subject matter jurisdiction. Fed. R. Civ. P. 12(h)(3). 1 As a result of Dr. Russo euthanizing Hank, Plaintiff’s property was raided, and other 2 animals in her possession were seized. Id. Plaintiff subsequently had a bench trial during 3 which Dr. Russo falsely testified that Hank “would not have been ‘as bad’ had he been 4 brought in sooner.” Id. Plaintiff has suffered severe emotional distress and trauma among 5 other damages resulting from the “cascading consequences” of Hank’s euthanasia. Id. 6 IV. Analysis 7 A. Federal Law Claim 8 The Complaint brings five counts: professional negligence and deprivation of 9 property without due process against Dr. Russo, corporate negligence/failure to supervise 10 against VCA, and intentional infliction of emotional distress and conversion/trespass to 11 chattels against both Defendants. See Doc. 1 at 3. Count Two, deprivation of property 12 without due process purportedly brought under 42 U.S.C. § 1983, is the only federal law 13 claim alleged in the Complaint. See id. Under this Count, Plaintiff argues that her service 14 animal was protected property under the Fourth Amendment, and Dr. Russo, “acting jointly 15 with law enforcement and under color of state authority, deprived Plaintiff of property 16 (Dr[.] Hank) without notice or opportunity to be heard.” Id. 17 Generally, the guarantees in the Constitution run only against federal and state 18 governments—not private individuals. See Edmonson v. Leesville Concrete Co., 500 U.S. 19 614, 619 (1991). In other words, state action is required. But “[a]lthough the conduct of 20 private parties lies beyond the Constitution’s scope in most instances, governmental 21 authority may dominate an activity to such an extent that its participants must be deemed 22 to act with the authority of the government and, as a result, be subject to constitutional 23 constraints.” Id. at 620. Only in limited circumstances can a private entity qualify as a state 24 actor, including, relevant here, “when the government compels the private entity to take a 25 particular action . . . [or] when the government acts jointly with the private entity.” 26 Manhattan Cmty. Access Corp. v. Halleck,587 U.S. 802, 809 (2019) (citations omitted). 27 Here, Plaintiff states Dr. Russo “act[ed] jointly with law enforcement and under 28 color of state authority” when she euthanized Hank. Doc. 1 at 3. But these words alone are 1 not enough to establish state action or state a claim under federal law. See Iqbal, 556 U.S. 2 at 678 (2009) (“Threadbare recitals of the elements of a cause of action, supported by mere 3 conclusory statements, do not suffice [to state a claim].”). None of Plaintiff’s factual 4 allegations support this claim. Plaintiff brings Count Two only against Dr. Russo, who is 5 a private citizen that Plaintiff does not allege works for a government entity.2 Nowhere in 6 the Complaint does Plaintiff allege any government entity was involved in the decision to 7 euthanize Hank. See generally Doc. 1. The only factual allegation that insinuates Dr. Russo 8 may have been involved in with any government entity is the claim that she testified at 9 Plaintiff’s bench trial, but this allegedly happened after Hank’s euthanasia and therefore 10 cannot support the deprivation of property claim. And, ultimately, the allegation flies in 11 the face of common sense. Plaintiff cannot manufacture a federal claim simply by stating 12 Dr.

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Erickson v. Pardus
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Ashcroft v. Iqbal
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Bartlett v. Strickland
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Sanford v. MemberWorks, Inc.
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Trista Tramposch di Genova v. Olivia Russo, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/trista-tramposch-di-genova-v-olivia-russo-et-al-azd-2026.