Yates v. Bates

CourtDistrict Court, W.D. Virginia
DecidedJanuary 26, 2021
Docket7:20-cv-00718
StatusUnknown

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

Bluebook
Yates v. Bates, (W.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA ROANOKE DIVISION

JAMES EDWARD YATES, ) Plaintiff, ) Civil Case No. 7:20-cv-00718 ) v. ) ) By: Elizabeth K. Dillon ROBERT BATES, et al., ) United States District Judge Defendants. )

MEMORANDUM OPINION

Plaintiff James Edward Yates, a Virginia inmate proceeding pro se, filed this action pursuant to 42 U.S.C. § 1983. The complaint is before the court for review pursuant to 28 U.S.C. § 1915A(a). For the reasons discussed herein, the court concludes that Yates’s complaint fails to state a claim for which relief can be granted, and so it must be dismissed without prejudice. I. BACKGROUND Yates’s complaint names three defendants: Robert Bates (who Yates describes as an officer with the Drug Task Force), Sheriff Hall, and the County of Alleghany. His complaint does not contain a lot of detail, but he alleges that he was cooperating with a drug task force and that Officer Bates “gave [him] immunity to possess guns [and] small amounts of drugs,” so he could “keep [his] image as a drug dealer.” (Compl. 2, Dkt. No. 1.) He says Bates specifically told him he would never be charged or prosecuted, but he “ended up receiving 20 years in prison without the immunity promised.” (Id.) He does not identify any actions taken by Sheriff Hall, nor does he offer any basis for finding liability on the part of Alleghany County. The only relief he seeks is ten million dollars in compensatory damages and five million dollars in punitive damages. Upon review of Yates’s complaint, the court concludes that his claims are subject to dismissal pursuant to 28 U.S.C. § 1915A(b)(1) for the reasons discussed next. II. DISCUSSION A. Yates Does Not State a Claim Against Sheriff Hall or the County of Alleghany

“To state a claim under § 1983, a plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” Loftus v. Bobzien, 848 F.3d 278, 284– 85 (4th Cir. 2017) (internal quotation marks omitted). Liability under § 1983 is “personal, based upon each defendant’s own constitutional violations.” Trulock v. Freeh, 275 F.3d 391, 402 (4th Cir. 2001) (internal citation omitted). Thus, a § 1983 claim requires factual detail about each defendant’s personal involvement. See Wilcox v. Brown, 877 F.3d 161, 170 (4th Cir. 2017) (explaining that liability will lie under § 1983 only “where it is affirmatively shown that the official charged acted personally” in the violation of plaintiff’s rights and affirming

dismissal of claim where plaintiff did not allege personal involvement by defendant) (quoting Vinnedge v. Gibbs, 550 F.2d 926, 928 (4th Cir. 1977)). Yates does not allege any action by Sheriff Hall. Moreover, to the extent he is attempting to hold Hall responsible under a theory of supervisory liability, he has wholly failed to allege any facts plausibly setting forth a supervisory liability claim. To establish such liability, Yates must allege facts sufficient to show that the defendant (1) “had actual or constructive knowledge that [a] subordinate was engaged in conduct that posed ‘a pervasive and unreasonable risk’ of constitutional injury to citizens like the plaintiff”; (2) that the defendant’s “response to that knowledge was so inadequate as to show ‘deliberate indifference to or tacit authorization of the alleged offensive practices,’”; and (3) that there was an “affirmative causal link” between the defendant’s conduct and plaintiff’s “particular constitutional injury.” Wilkins v. Montgomery, 751 F.3d 214, 226 (4th Cir. 2014) (quoting Shaw v. Stroud, 13 F.3d 791, 799 (4th Cir. 1994)). Although a pro se complaint is held to “less stringent standards than formal pleadings

drafted by lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal quotation marks and citation omitted), a complaint must still “contain sufficient factual matter, accepted as true, to ‘state a claim of relief that is plausible on its face,’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Yates’s complaint contains no facts whatsoever that could plausibly satisfy any of the foregoing three requirements. Yates also has failed to plead a viable claim against Alleghany County. “Local governing bodies . . . can be sued directly under § 1983 for monetary, declaratory, or injunctive relief where . . . the action that is alleged to be unconstitutional implements or executes a policy statement, ordinance, regulation, or decision officially adopted and promulgated by that body’s

officers.” Monell v. Dep’t of Soc. Servs. of N.Y.C., 436 U.S. 658, 690 (1978). Thus, a local governmental entity is liable under § 1983 only when the entity itself is a “moving force” behind the deprivation. Polk Cty. v. Dodson, 454 U.S. 312, 326 (1981). To satisfy that requirement, the entity’s official policy or custom must have played a part in the alleged violation of federal law. Oklahoma City v. Tuttle, 471 U.S. 808, 817–18 (1985). In this case, Yates has set forth no factual matter that would state a claim against the County under Monell. B. Yates’s Claim Is Barred by Heck v. Humphrey In addition to failing to state a claim against Hall or the County, the entirety of Yates’s complaint must be dismissed for a more fundamental reason. Specifically, his claim—which is essentially that he had been promised immunity for the very conduct that led to his conviction— is barred by Heck v. Humphrey, 512 U.S. 477 (1994). Heck precludes a § 1983 claim that would “necessarily imply the invalidity of [the plaintiff’s] conviction or sentence,” because “civil tort actions are not appropriate vehicles for

challenging the validity of outstanding criminal judgments.” Id. at 486–87. Instead, “habeas corpus is the appropriate remedy” for a state prisoner to challenge his conviction or sentence. Id. at 482. Heck thus held that if granting relief on a civil claim would necessarily call into question the validity of a criminal judgment, then the civil case cannot proceed unless the conviction has been “reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus, 28 U.S.C. § 2254.” Id. at 486–87.

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Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Denise Wilkins v. Vicki Montgomery
751 F.3d 214 (Fourth Circuit, 2014)
Christopher Covey v. Assessor of Ohio County
777 F.3d 186 (Fourth Circuit, 2015)
Nancy Loftus v. David Bobzien
848 F.3d 278 (Fourth Circuit, 2017)
Torrey F. Wilcox v. Betty Brown
877 F.3d 161 (Fourth Circuit, 2017)
Lomax v. Ortiz-Marquez
590 U.S. 595 (Supreme Court, 2020)
Shaw v. Stroud
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Trulock v. Freeh
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Bluebook (online)
Yates v. Bates, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yates-v-bates-vawd-2021.