Trotter v. GEO Group Inc

CourtDistrict Court, W.D. Oklahoma
DecidedOctober 15, 2024
Docket5:24-cv-00007
StatusUnknown

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

Bluebook
Trotter v. GEO Group Inc, (W.D. Okla. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

JARED M. TROTTER, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-00007-JD ) GEO GROUP INC., ) ) Defendant. )

ORDER

Before the Court is a Report and Recommendation issued by United States Magistrate Judge Amanda Maxfield Green. [Doc. No. 9]. Judge Green recommends that the Court dismiss Plaintiff Jared Trotter’s complaint [Doc. No. 1] against Defendant GEO Group, Inc. (“GEO Group”) for failure to plead municipal liability or a constitutional violation. Trotter objected. [Doc. No. 10]. Upon de novo review in accordance with 28 U.S.C. § 636(b)(1) and Federal Rule of Civil Procedure 72(b)(3), the Court accepts the Report and Recommendation and dismisses the complaint without prejudice. I. BACKGROUND Trotter, a state inmate currently incarcerated at the Lawton Correctional and Rehabilitation Facility, alleges in his complaint that he “has been found guilty of a class X [] misconduct wherein his cellmate admitted to placing the contraband in Plaintiff’s property without Plaintiff’s knowledge.” [Doc. No. 1 at 7]. Trotter claims that GEO Group violated the Equal Protection Clause of the Fourteenth Amendment because in his administrative proceedings, “Defendants did not accept the statement and found Plaintiff guilty, but permitted Brandon Michum . . . and Dillon Oquin . . . to use the same defense.” Id. Trotter alleges that he was “[t]reated different to similarly situated inmates with the same class of misconduct, same prison, housing unit, and circumstances

consistent with the fact [that] they have been permitted to submit exculpatory statement[s] from their cellmates in order to ensure the righteous discipline of inmates.” [Doc. No. 1-1 at 3]. “[I]n contrast,” Trotter argues, he “receiv[ed] reckless disregard to his exculpatory statement from his cellmate resulting in disproportionate or incorrect discipline to the wrong inmate/party.” Id. at 4. For relief, Trotter requests “(1) [f]or the

Court to overturn the finding of guilt on the misconduct on [the] basis of violating the equal protection clause of the constitution,” “(2) Compensatory damages of $200 and (3) Punitive damages of $1000.” [Doc. No. 1 at 7]. Judge Green screened this action pursuant to 28 U.S.C. § 1915A(a) and issued a Report and Recommendation recommending that the Court dismiss Trotter’s complaint

for failure to state a claim under 28 U.S.C. § 1915(e)(2). [Doc. No. 9]. The Report and Recommendation first notes that Heck v. Humphrey, 512 U.S. 477 (1994), likely would not bar Trotter’s claim because he does not challenge the duration of his confinement. Id. at 4–5. Nevertheless, Judge Green recommends that the Court dismiss his complaint for failure to plead municipal liability under Monell v. Department of Social Services of the

City of New York, 436 U.S. 658 (1978). Id. at 5–8. Specifically, the Report and Recommendation notes that Trotter “alleges no facts indicating that a written policy or failure to train or supervise caused a violation of his constitutional rights,” nor does he “identify a GEO Group final policymaker that made or ratified” decisions violating his rights or “allege multiple incidences of conduct that would establish an informal custom amounting to a widespread practice.” Id. at 7. Even if Trotter had plausibly alleged the existence of a policy or custom to support municipal liability, Judge Green recommends

dismissal because he failed to identify similarly situated individuals whom GEO Group treated differently to support an equal protection claim. See id. at 8. Although Trotter identified two other prisoners who allegedly raised the same defense as him, the “[u]se of the same method of defense in different proceedings involving different allegations of misconduct and different witnesses/participants does not demonstrate requisite

similarity.” Id. at 9. Thus, Judge Green recommends dismissal, and her Report and Recommendation notified Trotter of his right to object and the consequences of a failure to object. Id. at 9–10. In his objection, Trotter argues that he satisfied Monell because his administrative appeal was denied pursuant to an official policy and ratified by GEO Group

policymakers. [Doc. No. 10 at 2–3]. Regarding his equal protection claim, Trotter argues that he sufficiently alleged the requisite level of similarity because Class X and Class A misconducts are similar “[i]n all relevant respects”: they have the “same governing policy, same appeals process,” and lead to “exposure to identical punishment/sanctions.” Id. at 3.

II. LEGAL STANDARDS When a magistrate judge has entered a recommended disposition of a matter, the Court “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made,” and “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1). “[O]nly an objection that is sufficiently specific to focus the district court’s attention on the factual and legal issues that are truly in

dispute will . . . . preserve an issue for de novo review by the district court or for appellate review.” United States v. 2121 E. 30th St., 73 F.3d 1057, 1060 (10th Cir. 1996). “De novo review requires the district court to consider relevant evidence of record and not merely review the magistrate judge’s recommendation.” In re Griego, 64 F.3d 580, 584 (10th Cir. 1995).

Although Trotter is proceeding pro se and his filings are entitled to liberal construction, he is still subject to the same rules and requirements as a represented party, including the Federal Rules of Civil Procedure and the Court’s Local Civil Rules. See Kay v. Bemis, 500 F.3d 1214, 1218 (10th Cir. 2007); cf. In re Kirkland, 86 F.3d 172, 176 (10th Cir. 1996) (explaining that a pro se litigant’s ignorance of the rules does not excuse

him from following the rules). The Court addresses Judge Green’s Report and Recommendation pursuant to these standards. III. ANALYSIS Under Monell v. Department of Social Services of the City of New York, 436 U.S.

658 (1978), which extends to private entities operating correctional facilities under color of state law, “a plaintiff may sue local governing bodies directly for constitutional violations pursuant to the body’s policies.” Lucas v. Turn Key Health Clinics, LLC, 58 F.4th 1127, 1144 (10th Cir. 2023); see Smedley v. Corr. Corp. of Am., 175 F. App’x 943, 946 (10th Cir. 2005) (unpublished) (applying Monell to a private jail operator). “To state a claim against a municipal entity, a plaintiff must allege facts showing (1) an official policy or custom, (2) causation, and (3) deliberate indifference.” Lucas, 58 F.4th at 1145.

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

Related

Link v. Wabash Railroad
370 U.S. 626 (Supreme Court, 1962)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Smedley v. Corrections Corp. of America
175 F. App'x 943 (Tenth Circuit, 2005)
Kay v. Bemis
500 F.3d 1214 (Tenth Circuit, 2007)
United States v. 2121 East 30th Street
73 F.3d 1057 (Tenth Circuit, 1996)
Lucas v. Turn Key Health Clinics
58 F.4th 1127 (Tenth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Trotter v. GEO Group Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trotter-v-geo-group-inc-okwd-2024.