Whitten v. McCurtain County Jail Trust

CourtDistrict Court, E.D. Oklahoma
DecidedJune 13, 2025
Docket6:24-cv-00229
StatusUnknown

This text of Whitten v. McCurtain County Jail Trust (Whitten v. McCurtain County Jail Trust) is published on Counsel Stack Legal Research, covering District Court, E.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whitten v. McCurtain County Jail Trust, (E.D. Okla. 2025).

Opinion

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

MARION ALLEN WHITTEN, JR., ) ) Plaintiff, ) ) v. ) Case No. CIV-24-229-RAW-GLJ ) MCCURTAIN COUNTY JAIL TRUST; ) LARRY HENDRIX, individually and in ) his official capacity; TRENT ) MITCHELL; JOE EBERT; and ) TYLER SIVARDS, individually, ) ) Defendants. )

REPORT AND RECOMMENDATION

This matter comes before the Court on motions for partial dismissal and/or total dismissal by all remaining Defendants in this case. Plaintiff Marion Allen Whitten sues, inter alia, former jailer Trent Mitchell, alleging various Fourth and Fourteenth Amendment violations pursuant to 42 U.S.C. § 1983, arising out of his incarceration at the McCurtain County Jail in Idabel, Oklahoma. Mitchell moves to dismiss all of Plaintiff’s claims against him. For the reasons set forth below, the undersigned Magistrate Judge recommends that Defendant Trent Mitchell’s Motion to Dismiss Plaintiff’s First Amended Complaint and Brief in Support [Docket No. 71] be GRANTED IN PART and DENIED IN PART. PROCEDURAL HISTORY & BACKGROUND In broad terms, Plaintiff’s First Amended Complaint alleges two separate instances in which excessive force was used against him while he was in custody at the McCurtain County Jail. Plaintiff alleges the first incident occurred on January 1, 2022, when he and jailed Joe Ebert had an argument, at which time Ebert and jailer Tyler Sivard escorted him

out of his cell and placed him in a restraint chair. Docket No. 68, pp. 13-14, ¶¶ 79-83. Plaintiff asserts that, immediately after he was placed in the restraint chair, Ebert “unnecessarily and without provocation began to beat Plaintiff about the head and body striking him several times,” such as to constitute excessive force. Id., ¶¶ 83, 85-89. He alleges Sivard was present but did nothing to intervene and did not report it. Id., ¶¶ 84-85, 89, 92. Four days later, Ebert failed to report to work, which was sufficient to consider

him terminated. Id., p. 15, ¶¶ 99, 102. The second incident occurred in April 2022, after Plaintiff “attempted to gain the attention of jailers by tapping the isolation cell camera,” in order to ask about his previous grievances. Id., p. 20, ¶ 127-127. Plaintiff alleges that in response, jailer Trent Mitchell assaulted him with the JPX 4 Jet Defender pepper ball gun and again locked him in the

isolation cell, making him wait thirty minutes before allowing him to shower and “humiliating him while laughing aloud.” Id., ¶ 129-130. In the immediately following paragraphs, Plaintiff refers to the actions of Mitchell, as well as Ebert and Sivard (despite there being no allegation Ebert or Sivard was present for the April 2022 incident). Id., ¶¶ 131-138.

Plaintiff first filed suit on these events on January 4, 2023, by filing a pro se prisoner civil rights claim. See Eastern District of Oklahoma Case No. CIV-23-005-JFH-GLJ, Docket Nos. 1-2 (“Original Case”). The original Complaint named Defendants McCurtain County Jail Trust (“MCJT”), Larry Hendrix, Joe LNU, and J.C. LNU [Docket No. 1]. In that Complaint, Plaintiff identified one claim related to the January 2022 incident, but he also stated, “Another incident in which I was J.P.X. pepper balled for hitting camera is how

I informed proper person of incidence with happened earlier in year of 2022!” (Original Case, Docket No. 1, p. 5). On January 20, 2023, Plaintiff filed an Amended Complaint, naming Defendants Hendrix, Joe LNU, and Mitchell [Id., Docket No. 6]. In this Amended Complaint, Plaintiff’s second claim asserts, as relevant, “While in isolation cell I was hitting camera for attention and Trent Mitchel working as Day Shift Supervisor, J.P.X. Pepper ball me 3-5 times and shut the door and left me in there for 30 minutes to an 1 hour

before letting me out to shower, only supplied small ounce of detergent to wash off and was laughing at me while/thru entire event.” Id., Docket No. 6, p. 5. On February 14, 2023, Plaintiff filed a Second Amended Complaint, naming MCJT, Joe Zappala, Hendrix, and J.C. “MacMillon” [Id.,Docket No. 8]. Plaintiff’s second claim in this iteration referenced June 2022, but stated, “On this day on about in 2022, Marion Allen Whitten Jr.

was J.P.X. pepperballed while in isolation cell and left for 30 min to hr before being allowed to shower pepper spray off, for alledgely [sic] hitting camera, Larry Hendrix and J.C. MacMillon allowed officers-jailers to violate cruel and unusual punishment by ignoring or “Losing” grievances filed on paper on both occurrences.” Id., Docket No. 8, p. 5. The Court granted Plaintiff in forma pauperis status in this original case, but

ultimately dismissed the case on July 13, 2022, for his failure to pay the initial filing fee and failing to advise the Court of his change of address [Docket Nos. 11, 14]. Plaintiff, represented by counsel, filed the present case on July 5, 2024 [Docket Nos. 1-2] (“Present Case”), naming the MCJT; Hendrix, in his individual capacity and in his official capacity as McCurtain County Jail Administrator; Mitchell; Ebert; Sivard, individually and in his official capacity; and James McMillen, jailer and Assistant Jail

Administrator. The Court referred this case to the undersigned Magistrate Judge for all pretrial and discovery matters, pursuant to 28 U.S.C. § 636(b) and Fed. R. Civ. P. 72 [Docket No. 49]. Upon invitation by the Court, Plaintiff filed his First Amended Complaint on March 5, 2025, which no longer named Tyler Sivard in his official capacity [Docket No. 68]. Each remaining Defendant now moves for partial or full dismissal of the First Amended Complaint [Docket Nos. 70-73].

Plaintiff alleges seven causes of action in his First Amended Complaint: (I) § 1983 claim for a Fourth Amendment violation by use of excessive force, as to Ebert and Mitchell; (II) § 1983 claim for a Fourth Amendment violation by failing to intervene to prevent or stop the use of excessive force, as to Ebert, Mitchell, and Sivard; (III) § 1983 of failing to adequately train, supervise, and/or control, as to Hendrix in his official capacity

and MCJT; (IV) § 1983 claim for a Fourteenth Amendment violation by deliberate indifference to serious medical needs of a pretrial detainee, as to Hendrix, Mitchell, McMillen, Ebert, and Sivard; (V) § 1983 claim for a Fourteenth Amendment violation by deliberate indifference to health and safety of a pretrial detainee, as to Hendrix, Mitchell, McMillen, Ebert, and Sivard; (VI) § 1983 claim for a Fourteenth Amendment violation by

use of excessive force against a pretrial detainee, as to Hendrix, Mitchell, McMillen, Ebert, and Sivard; and (VII) § 1983 municipal liability claim under Monell1 as to MCJT. After

1 Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978). responsive briefing on the motions wherein Plaintiff agreed McMillen should be dismissed, Plaintiff filed a Joint Stipulation of dismissal, dismissing the claims against McMillen with

prejudice [Docket Nos. 72, 78-79]. Plaintiff’s First Amended Complaint, like the Original Case, is based on the two main incidents from January and April 2022, but Plaintiff’s causes of action do not distinguish between the January 2022 and April 2022 incidents instead lumping the actors together. In total, Plaintiff names Mitchell in five claims. Mitchell moves to dismiss all of Plaintiff’s claims against him.

Legal Standards

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Whitten v. McCurtain County Jail Trust, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitten-v-mccurtain-county-jail-trust-oked-2025.