VICENTY v. STATE OF NEW JERSEY

CourtDistrict Court, D. New Jersey
DecidedFebruary 28, 2025
Docket1:24-cv-10999
StatusUnknown

This text of VICENTY v. STATE OF NEW JERSEY (VICENTY v. STATE OF NEW JERSEY) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VICENTY v. STATE OF NEW JERSEY, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

BRIAN VICENTY, Plaintiff aus Civil Action No. 24-10999 (KMW) (MIS) OPINION RORY BUCHANAN, et al, Defendants.

WILLIAMS, District Judge: This matter comes before the Court on the Court’s sua sponte screening of Plaintiff's amended complaint (ECF No. 3) and the Court’s review of Plaintiff's application to proceed in forma pauperis (ECF No. 6). Having reviewed the application, this Court finds that leave to proceed in forma pauperis is warranted in this matter, and the application is granted. Because Plaintiff shall be granted i# forma pauperis status in this matter, this Court is required to screen his complaint pursuant to 28 U.S.C. § 1915(e)(2)(B) and dismiss any claim which is frivolous, malicious, fails fo state a claim for relief, or seeks relief from an immune defendant. For the reasons set forth below, Plaintiff's amended complaint is dismissed without prejudice for failure to state a claim for which relief may be granted.

I. BACKGROUND Plaintiff is a state prisoner currently awaiting trial on unspecified charges. (ECF No. 3 at 3-4.) In his amended complaint, Plaintiff asserts that he was detained in a police station on April

23, 2024, for several hours before he was told he would not be arrested, waived his rights, and then spoke with police. (Ud) Plaintiff contends that this interrogation was in violation of his Fifth Amendment rights, but does not elaborate on why he believes this to be the case, Gd) Plaintiff also asserts that one of the Defendants “lied” to secure a search warrant, but does not detail what the lie was, how it affected the warrant, or the like. (éd.) Finally, Plaintiff alleges he is being maliciously prosecuted for “false charges” on which he does not elaborate and that his appointed counsel is ineffective. Ud.) Plaintiff, however, does not name his counsel, as a Defendant, and thus does not appear to be pursuing a claim for ineffective assistance of counsel at this time. (d. at 2.)

i. LEGAL STANDARD Because Plaintiff shall be granted it forma pauperis status, this Court is required to screen his amended complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). Pursuant to the statute, this Court must sua sponte dismiss any claim that is frivolous, malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. id. “The legal standard for dismissing a complaint for failure to state a claim pursuant to 28 U.S.C, § 1915(e)(2)(B) (ii) is the same as that for dismissing a complaint pursuant to Federal Rule of Civil Procedure 12(b)(6).” Schreane v. Seana, 506 F. App’x 120, 122 Gd Cir, 2012) (citing Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir, 2000)). In deciding a motion to dismiss pursuant to Fed, R. Civ, P, 12(b)(6), a district court is required to accept as true all factual allegations in the complaint and draw all reasonable inferences from those allegations in the light most favorable to the plaintiff, see Phillips v. Cnty. of Allegheny, 515 F.3d 224, 228 Gd Cir, 2008), but need not accept as true legal conclusions couched as factual allegations, Papasan v. Allain, 478 U.S. 265, 286 (1986). A complaint need not contain “detailed

factual allegations” to survive a motion to dismiss, but must contain “more than an unadorned, the- defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A complaint “that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do,’” and a complaint will not “suffice” if it provides only “’naked assertion[s]’ devoid of ‘further factual enhancement.’” /d. (quoting Bell Atlantic v. Twombly, 550 U.S. 544, 555, 557 (2007)). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.” Jd (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is lable for the misconduct alleged.” Jd. (quoting Twombly, 550 U.S, at 556). A complaint that provides facts “merely consistent with” the defendant’s liability “stops short of the line between possibility and plausibility” and will not survive review under Rule 12(b)(6). Jd. (quoting 7iwombly, 555 U.S. at 557). While pro se pleadings are to be liberally construed in conducting such an analysis, pro se litigants must still “allege sufficient facts in their complaints to support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir, 2013).

HI. DISCUSSION In his complaint, Plaintiff appears to be raising claims for false arrest, false imprisonment, malicious prosecution, a violation of his self-incrimination rights, and a violation of his Fourth Amendment rights in light of a search arising out of an allegedly faulty warrant. Plaintiff names as Defendants two police officers, the Paterson Police Department, and the State of New Jersey. Neither the Paterson Police Department nor the State of New Jersey are persons subject to suit under federal civil rights laws, and any claims Plaintiff has against them must therefore be

dismissed with prejudice at this time. See, e.g., Mikhaeil v. Santos, 646 F. App’x 158, 163 (3d Cir. 2016); Grohs v. Yatauro, 984 F. Supp. 2d 273, 280 (D.N.J. 2013). Turning to Plaintiffs Fifth Amendment claim, Plaintiff appears to be alleging that he was interrogated improperly without a valid waiver of his rights in light of the alleged lies of the officers and the time he was meant to remain in the police station before he waived his rights. Even if Plaintiff could show that there was a violation of his Miranda rights, it does not follow that he can state a claim for a violation of his Fifth Amendment rights in a civil rights suit. This is because while Miranda and its progeny concerning proper warnings prior to custodial interrogation announced prophylactic rules designed to protect a criminal defendant’s rights, a violation of a prisoner’s Fifth Amendment rights against self-incrimination occurs only when an allegedly improper confession is used against him at trial. See Chavez v. Martinez, 538 U.S. 760, 773 (2003); Renda v. King, 347 F.3d 550, 557 (3d Cir. 2003); Giuffre v. Bissell, 31 F.3d 1241, 1256 (3d Cir. 1994); see also Large v. Cnty. Of Montgomery, 307 F. App’x 606, 607 (3d Cir. 2009).

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

Related

Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Chavez v. Martinez
538 U.S. 760 (Supreme Court, 2003)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Michael Malik Allah v. Thomas Seiverling
229 F.3d 220 (Third Circuit, 2000)
Cheryl James v. Wilkes Barre City
700 F.3d 675 (Third Circuit, 2012)
Clarence Schreane v. Seana
506 F. App'x 120 (Third Circuit, 2012)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Byron Halsey v. Frank Pfeiffer
750 F.3d 273 (Third Circuit, 2014)
Stanford Large v. County of Montgomery
307 F. App'x 606 (Third Circuit, 2009)
Adel Mikhaeil v. Angel Santos
646 F. App'x 158 (Third Circuit, 2016)
Sherwood v. Mulvihill
113 F.3d 396 (Third Circuit, 1997)
Grohs v. Yatauro
984 F. Supp. 2d 273 (D. New Jersey, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
VICENTY v. STATE OF NEW JERSEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vicenty-v-state-of-new-jersey-njd-2025.