Vincent Caccavale v. Onslow County

District Court, E.D. North Carolina·Decided July 8, 2026·No. 7:25-cv-01028·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA SOUTHERN DIVISION No. 7:25-CV-1028-BO-KS VINCENT CACCAVALE, ) Plaintiff, ) Vv. ‘ORDER ONSLOW COUNTY, Defendant.

This cause comes before the Court on defendant’s moron to dismiss for failure to state a claim. [DE 22]. Plaintiff has responded [DE 25], defendant has replied [DE 26], and plaintiff has proposed a sur-reply [DE 27-1]. The Court also considers plaintiffs motion for leave to file a third amended complaint. [DE 28]. Defendant responded [DE 29] and plaintiff replied [DE 30]. In this posture, the motions are ripe for ruling. For the following reasons, defendant’s motion to dismiss is granted and the motion for leave to amend is denied. BACKGROUND Plaintiff appears in this action pro se. On December 16, 2024, he and his service dog Hank sat as spectators in the gallery of Courtroom 8 in the Onslow County Courthouse. [DE 14, § 12]. Plaintiff left to use the restroom, and on his return, Deputy Benjamin Donovan asked him if the dog was a service animal. Jd. Plaintiff assured him the dog was a service animal. Jd. When the court recessed, presiding Judge Ashley Gore asked plaintiff to approach the bar. Jd. at 13. She asked if the dog was a service animal, and plaintiff assured her so. Judge Gore asked for the dog’s documentation, and plaintiff “informed Judge Gore that, under the ADA, there is no documentation required for service animals, and that the only permissible questions are whether

the dog is a service animal and what tasks it performs.” Jd. Plaintiff and the dog were escorted from the courtroom. Jd. Plaintiff returned for the afternoon session with a letter from a doctor stating his disability diagnosis and recommending he use a service animal. Jd. at 15. He gave the letter to Deputy Donovan, who passed the letter to Judge Gore. Judge Gore asked plaintiff for documentation that the dog was credentialed by the ADA, seeking assurance that the dog had been properly vetted and trained. Jd. When plaintiff provided none, he and the dog were again expelled from the courtroom. Id. at 719. The operative complaint asserts two claims against the sole defendant, Onslow County. First, that it violated Title I! of the ADA. [DE 14, 9] 39-50]. Second, that it violated § 504 of the Rehabilitation Act. [DE 14, J§ 51-62]. Plaintiff has also moved [DE 28] for leave to file a third amended complaint, adding additional defendants and claims. STANDARD A 12(b)(6) motion to dismiss for failure to state a claim upon which relief can be granted tests the complaint’s legal and factual sufficiency. See Fed. R. Civ. P. 12(b)(6). The focus is on the pleading requirements under the Federal Rules, not the proof needed to succeed on a claim. “Federal Rule of Civil Procedure 8(a)(2) requires only a short and plain statement of the claim showing that the pleader is entitled to relief, in order to give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (cleaned up). This standard does not require detailed factual allegations, id., but it “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Nadendla □□□ WakeMed, 24 F.4th 299, 305 (4th Cir. 2022) (citation omitted). “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.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). Fora claim to be plausible, its factual content must permit the court to “draw the reasonable inference that the defendant is liable for the misconduct alleged.” Jd. DISCUSSION J. Operative Complaint Under Monell, a local government can be held liable under 42 U.S.C. § 1983 for its unconstitutional policies. 436 U.S. 658, 690-94 (1978). Municipal liability results only “when execution of a government’s policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy, inflicts the injury.” Jd at 694. Municipal liability is not available under the theory of respondeat superior. Milligan v. City of Newport News, 743 F.2d 227, 229 (4th Cir. 1984). A policy or custom for which a municipality may be held liable can arise in four ways: (1) through an express policy, such as a written ordinance or regulation; (2) through the decisions of a person with final policymaking authority; (3) through an omission, such as a failure to properly train officers, that ‘manifest[s] deliberate indifference to the rights of citizens’; or (4) through a practice that is so persistent and widespread as to constitute a custom or usage with the force of law. Lytle v. Doyle, 326 F.3d 463, 471 (4th Cir. 2003) (internal quotations omitted). Plaintiff argues Onslow County is liable under Monell for failing “to adequately train, supervise, or discipline its employees, including judges, deputies, and other court personnel, regarding the rights of individuals with disabilities and the lawful use of service animals in public facilities.” [DE 14, p. 13]. Unlike constitutional claims brought under 42 U.S.C. § 1983, claims under Title II of the ADA and § 504 of the Rehabilitation Act arise directly under those statutes, and need not be asserted through § 1983 or Monell. “In enacting Title IJ of the ADA, Congress made it specifically applicable to the States and state entities[.]” Fauconier v. Clarke, 966 F.3d 265, 280 (4th Cir.

2020). “The Fourth Circuit has... held that a private right of action exists under Section 504 against a State entity.” Shepard v. Irving, 204 F. Supp. 2d 902, 910 (E.D. Va. 2002) (citing Davis .

v. Southeastern Cmty Coll., 574 F.2d 1158 (4th Cir. 1988), rev’d on other grounds, Southeastern Cmty Coll., v. Davis, 442 U.S. 397 (1979)). See also Paulone v. City of Frederick, 787 F. Supp. 2d 360, 371 (D. Md. 2011).

The proper theory of municipal liability aside, plaintiff fails to state a claim because the acts of which he complains cannot fairly be attributed to defendant Onslow County. North Carolina judges “are employed by the State, not the County[.]” Covington v. North Carolina, 1:25CV347, 2025 U.S. Dist. LEXIS 134351, *1 (M.D.N.C. May 14, 2025). Deputies are not employees of the County either. Knight v. Vernon, 214 F.3d 544, 552 (4th Cir. 2000).

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