WHALEY v. CITY OF ALBANY GEORGIA

CourtDistrict Court, M.D. Georgia
DecidedMarch 24, 2025
Docket1:23-cv-00217
StatusUnknown

This text of WHALEY v. CITY OF ALBANY GEORGIA (WHALEY v. CITY OF ALBANY GEORGIA) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WHALEY v. CITY OF ALBANY GEORGIA, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA ALBANY DIVISION

JAMES EDWARD WHALEY, : : Plaintiff, : : v. : CASE NO.: 1:23-CV-217 (LAG) : CITY OF ALBANY, et al., : : Defendants. : : ORDER Before the Court is Defendants’, City of Albany and Brentten Robert Laethem, Motion to Dismiss and Incorporated Memorandum of Law in Support (Doc. 3) and Defendant Jenna Laethem’s Motion to Dismiss and Memorandum of Law in Support Thereof (Doc. 4). For the reasons below, the Motions (Docs. 3, 4) are GRANTED. BACKGROUND This action arises out of an altercation that occurred on December 10, 2017, between Plaintiff James Edward Whaley and Defendants Brentten and Jenna Laethem. (Doc. 1 ¶ 9). Around noon that day, Plaintiff was soliciting donations near the entrance to the Walmart parking lot in Lee County, Georgia.1 (Doc. 1 ¶ 9). Defendant Brentten Laethem, an off- duty police officer for Defendant City of Albany, and his wife, Defendant Jenna Laethem, witnessed Plaintiff accepting money from a passerby. (Id. ¶¶ 10–11). Defendant Brentten Laethem, after speaking to his wife, approached Plaintiff and instructed Plaintiff that he should not be asking people for money. (Id. ¶¶ 12–13). Defendant Brentten Laethem advised Plaintiff that if Plaintiff was still there soliciting money when Defendant Brentten Laethem and his wife finished shopping that “Plaintiff would be going to jail.” (Id.). Thirty

1 On a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the Court accepts all facts alleged in Plaintiff’s Complaint (Doc. 1) as true. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007); Anderson v. Wilco Life Ins., 17 F.4th 1339, 1344 (11th Cir. 2021) (citation omitted). minutes later, Defendants Brentten and Jenna Laethem approached Plaintiff again. (Id. ¶ 15). Defendant Brentten Laethem displayed his firearm and badge and said, “What did I tell you mother f—r.” (Id.). Defendant Brentten Laethem then pushed Plaintiff against a nearby lamp pole and began to search Plaintiff’s pants pockets and other outer garments without Plaintiff’s consent. (Id. ¶ 16). While searching Plaintiff’s garments, Defendant Brentten Laethem yelled to Defendant Jenna Laethem “watch him.” (Id. ¶ 17). Plaintiff protested that he had not committed any crime. (Id.). Shortly thereafter, a Lee County Sherriff’s deputy arrived at the scene. (Id. ¶ 21). Defendant Brentten Laethem had reported to the Lee County 911 dispatch that Plaintiff was banging on windows and accepting money from motorists. (Id. ¶ 22). Later, Defendant Bretten Laethem stated that Defendant Jenna Laethem had seen Plaintiff banging on windows but that he had not. (Id. ¶ 23). The responding deputy arrested Plaintiff. (Id. ¶ 24). Six years after his arrest, Plaintiff filed this action on December 11, 2023. (Doc. 1). The Complaint asserts 42 U.S.C. § 1983 claims under the Fourth and Fourteenth Amendments to the United States Constitution against Defendants Jenna and Brentten Laethem in Count I and against the City of Albany in Count II. (Id. ¶¶ 25–27). Plaintiff also asserts state law claims for assault, battery, false arrest, false imprisonment and conversion against Defendants Jenna and Brentten Laethem in Count III. (Id. ¶¶ 28–29). Defendants the City of Albany and Brentten Laethem filed a Motion to Dismiss on March 28, 2024, and Defendant Jenna Laethem filed a Motion to Dismiss on March 29, 2024. (Docs. 3, 4). Plaintiff responded on May 1, 2024. (Doc. 8). Defendants City of Albany and Brentten Laethem replied on May 6, 2024, and Defendant Jenna Laethem replied on May 13, 2024. (Docs. 10–12). Thus, the Motions are ripe for review. M.D. Ga. LR. 7.3.1(A). LEGAL STANDARD To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), “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). A claim is plausible on its face if the complaint alleges enough facts to “allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citation omitted). A complaint must plead “enough fact[s] to raise a reasonable expectation that discovery will reveal evidence” of the defendant’s liability. Twombly, 550 U.S. at 556. The Court must “take the factual allegations in the complaint as true and construe them in the light most favorable to the plaintiffs,” but the same liberal reading does not apply to legal conclusions. Anderson, 17 F.4th at 1344–45 (first citing Edwards v. Prime, Inc., 602 F.3d 1276, 1291 (11th Cir. 2010); and then citing Iqbal, 556 U.S. at 678). “[A] plaintiff armed with nothing more than conclusions” cannot “unlock the doors of discovery[.]” Iqbal, 556 U.S. at 678–79. Additionally, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. at 678 (citation omitted). DISCUSSION Defendants argue that Plaintiff’s § 1983 and state law claims are barred by the applicable statute of limitations. (Doc. 3 at 3; Doc. 4 at 2–3). Defendant Brentten Laethem also argues that the official capacity claims against him should be dismissed “on the ground that they are duplicative of [P]laintiff’s claims against the City.” (Doc. 3 at 5). I. Section 1983 Claims Section 1983 claims are governed by Georgia’s two-year statute of limitations for personal injury claims. Nance v. Commissioner, Ga. Dep’t of Corr., 59 F.4th 1149, 1153 (11th Cir. 2023) (“A claim brought under section 1983 is subject to the state statute of limitations governing personal injury actions, which is two years in Georgia.” (citations omitted)); see O.C.G.A. § 9-3-33. Federal courts “generally refer[] to state law for tolling rules[,]” and the burden is on the plaintiff to establish that the statute of limitations should be tolled once the defendant establishes that the suit was filed more than two years after the cause of action accrued. Wallace v. Kato, 549 U.S. 384, 394 (2007); Toliver v. Dawson, 896 S.E.2d 714, 716 (Ga. Ct. App. 2023). Defendants argue that Plaintiff’s claims are barred by the two-year statute of limitations because the alleged constitutional violations occurred on December 10, 2017 and Plaintiff did not file the Complaint until December 11, 2023—six years later. (Doc. 3 at 3; Doc. 4 at 2–3). Plaintiff does not argue that the two- year statute of limitations does not apply. (Doc. 8 at 3–4). Rather, Plaintiff argues that the statute of limitations was tolled pursuant to O.C.G.A. § 9-3-99. (Id.). Section 9-3-99 tolls the running of the statute of limitations “with respect to any cause of action in tort that may be brought by the victim of an alleged crime which arises out of the facts and circumstances relating to the commission of such alleged crime.” Section 9-3-99 is inapplicable for a host of reasons.

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Related

Edwards v. Prime, Inc.
602 F.3d 1276 (Eleventh Circuit, 2010)
Meredith T. Raney, Jr. v. Allstate Insurance Co.
370 F.3d 1086 (Eleventh Circuit, 2004)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Sarah Jenkins v. Kyle C. Keown
830 S.E.2d 498 (Court of Appeals of Georgia, 2019)
Vanessa Anderson v. Wilco Life Insurance Company
17 F.4th 1339 (Eleventh Circuit, 2021)

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Bluebook (online)
WHALEY v. CITY OF ALBANY GEORGIA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whaley-v-city-of-albany-georgia-gamd-2025.