Castro v. New Jersey
| Decision Date | 22 February 2021 |
| Docket Number | 1:15-cv-02041-NLH-JS |
| Court | U.S. District Court — District of New Jersey |
| Parties | Michael CASTRO, Plaintiff, v. State of NEW JERSEY, Michael Mattioli, James Rauch, Bruce Deshields, Darren Dooley, and Mullica Township, Defendants. |
DOUGLAS L. CODY, CODY & CODY, ESQS., 653 WHITE HORSE PIKE, HAMMONTON, NJ 08037, MARTIN P. DUFFEY, COZEN AND O'CONNOR, LIBERTY VIEW BLDG., 457 HADDONFIELD RD - SUITE 300, CHERRY HILL, NJ 08002, On behalf of Plaintiff.
ROBERT J. MCGUIRE, NEW JERSEY OFFICE OF THE ATTORNEY GENERAL, 25 MARKET STREET, P.O. BOX 116, TRENTON, NJ 08625, On behalf of Defendants State of New Jersey, Michael Mattioli, James Rauch, Bruce DeShields, and Darren Dooley.
THOMAS B. REYNOLDS, REYNOLDS & HORN, P.C., 750 ROUTE 73 SOUTH-SUITE 202A, MARLTON, NJ 08053, On behalf of Defendant Mullica Township.
This matter concerns constitutional and state law claims by Plaintiff arising out of his arrests and grand jury indictments for murder and other charges, all of which were ultimately dismissed. Presently before the Court are Defendants’ motions for summary judgment. For the reasons expressed below, the State Defendants’ motion will be denied, and Mullica Township's motion will be granted.
Plaintiff, Michael Castro, was arrested on April 9, 2013 and indicted by a grand jury on July 3, 2013 for the February 5, 2012 murder of John Kingsbury in Mullica Township, Atlantic County, New Jersey. On June 30, 2014, the New Jersey Superior Court granted Plaintiff's motion to dismiss the indictment, finding that the Grand Jury did not have "an entirely accurate presentation of the evidence in order to determine whether there was reason to believe that the crimes alleged were committed by [Castro]." After having been incarcerated for sixteen months, Plaintiff was released from custody on August 8, 2014 because the Atlantic County Prosecutor's Office did not re-indict him within the 45 days afforded by the Superior Court.
On March 20, 2015, Plaintiff filed the instant case against the Atlantic County Prosecutor's Office (ACPO), Mullica Township, and Atlantic County, as well as numerous actors involved in the investigation of the Kingsbury murder, including the ACPO prosecutors, the ACPO investigators, and the Mullica Township police officer who assisted in the ACPO's investigation. On May 29, 2015, Plaintiff filed an amended complaint, and simultaneously filed a similar complaint in New Jersey Superior Court.
The ACPO Defendants, hereinafter referred to as the State Defendants,1 removed Plaintiff's state court complaint, which was later consolidated with this case. The State Defendants and Atlantic County filed motions to dismiss.2
While those motions were pending, on January 26, 2016, an Atlantic County Grand Jury again indicted Plaintiff on nine counts, including a count for the first-degree murder of Kingsbury. Pursuant to a warrant on indictment, Plaintiff was arrested on January 27, 2016. Plaintiff was released on $250,000 bail. On March 31, 2016, this Court administratively terminated the case until Plaintiff's criminal case had reached its final resolution. (Docket No. 53.)
On February 22, 2017, Plaintiff filed a motion to dismiss the second indictment. A hearing on the motion to dismiss the indictment was scheduled for May 25, 2017, but in advance of that hearing, the ACPO moved to dismiss the case on its own accord. On May 23, 2017, the Atlantic County Superior Court entered an Amended Order dismissing the indictment, discharging the bail, and ordering the release of Plaintiff from custody.
This Court reopened the matter on May 31, 2017. Plaintiff filed a second amended complaint on September 11, 2017, while again simultaneously filing an almost identical complaint in New Jersey Superior Court. The State Defendants removed that case, which was then consolidated with this action. The Mullica Township Defendants filed their answer on November 10, 2017, and the State Defendants and Atlantic County moved to dismiss Plaintiff's second amended complaint on November 13, 2017. On June 25, 2018, the Court granted in part and denied in part the motions to dismiss. (Docket No. 99, 100.)
On December 2, 2019, the Mullica Township Defendants and the State of New Jersey Defendants filed motions for summary judgment. On December 4, 2019, the Magistrate Judge granted Plaintiff's motion for leave to file a third amended complaint. On December 9, 2019, Plaintiff filed his third amended complaint, which re-added as a Defendant Joseph Rauch, a detective for the Atlantic County Prosecutor's Office who had previously been dismissed as a defendant. On June 2, 2020, Rauch filed a motion for summary judgment as to Plaintiff's claims against him in Plaintiff's third amended complaint.3
In his 229-page, 1228-paragraph third amended complaint, Plaintiff alleges that Defendants willfully, recklessly, and callously disregarded his rights under federal and state law by blatantly ignoring evidence pointing to other suspects, fabricating evidence and misrepresenting the actual facts adduced through investigation, and failing to obtain and preserve critical evidence, including evidence that likely would have exculpated him and exposed third parties who actually committed or participated in the homicide. Plaintiff has asserted nine counts for violations of his rights under the Fourth and Fourteenth Amendments of the U.S. Constitution, the New Jersey Civil Rights Act, and for the common law torts of false arrest, false imprisonment, malicious prosecution, civil conspiracy, negligence, intentional infliction of emotional distress, and negligent hiring.
All Defendants have moved for summary judgment on various bases. Plaintiff has opposed Defendants’ motions.4 In support of their positions, the parties have submitted voluminous briefing and thousands of pages of exhibits. The State Defendants have succinctly framed the focus of the viability of Plaintiff's claims: Has Plaintiff demonstrated genuine issues of material fact that his constitutional and state law rights were violated by an arrest and prosecution without probable cause, and with deliberate indifference or malice, or has he merely shown that Defendants could have performed a better investigation, which, even if true, is insufficient to support Plaintiff's claims?
The Court finds that Plaintiff has met his burden to defeat the State Defendants’ motion for summary judgment. However, the Court will grant Mullica Township's motion for summary judgment on a basis different from the underlying substance of Plaintiff's claims against it.
This Court has jurisdiction over Plaintiff's federal claims under 28 U.S.C. § 1331, and supplemental jurisdiction over Plaintiff's state law claim pursuant to 28 U.S.C. § 1367.
Summary judgment is appropriate where the Court is satisfied that the materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations, admissions, or interrogatory answers, demonstrate that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Celotex Corp. v. Catrett, 477 U.S. 317, 330, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986) ; Fed. R. Civ. P. 56(a).
An issue is "genuine" if it is supported by evidence such that a reasonable jury could return a verdict in the nonmoving party's favor. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). A fact is "material" if, under the governing substantive law, a dispute about the fact might affect the outcome of the suit. Id. In considering a motion for summary judgment, a district court may not make credibility determinations or engage in any weighing of the evidence; instead, the non-moving party's evidence "is to be believed and all justifiable inferences are to be drawn in his favor." Marino v. Industrial Crating Co., 358 F.3d 241, 247 (3d Cir. 2004) (quoting Anderson, 477 U.S. at 255, 106 S.Ct. 2505 ).
Initially, the moving party has the burden of demonstrating the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). Once the moving party has met this burden, the nonmoving party must identify, by affidavits or otherwise, specific facts showing that there is a genuine issue for trial. Id. Thus, to withstand a properly supported motion for summary judgment, the nonmoving party must identify specific facts and affirmative evidence that contradict those offered by the moving party. Anderson, 477 U.S. at 256-57, 106 S.Ct. 2505. A party opposing summary judgment must do more than just rest upon mere allegations, general denials, or vague statements.
The State Defendants consist of: Darren Dooley, a member of the ACPO and a captain in the Major Crimes Unit who supervised the investigation of the Kingsbury murder; Bruce DeShields, a member of the ACPO and the chief of the Major Crimes Unit who supervised the investigation of the Kingsbury murder; Michael Mattioli, a member of the ACPO and a sergeant in the Major Crimes Unit who was the lead detective in the investigation of the Kingsbury murder; and Joseph Rauch, a member of the ACPO and a detective assigned to the Major Crimes Unit who assisted in the investigation of the Kingsbury murder.5
The assessment of Plaintiff's claims against these Defendants must be broken down into two categories – (1) claims for the violations of Plaintiff's rights under the U.S. Constitution and the New Jersey Civil Rights Act, N.J.S.A. 10:6–2(c), and (2) Plaintiff's other state law claims.
(1) Plaintiff's U.S. Constitution and NJCRA violation claims
Plaintiff claims that the State Defendants violated his right to be free from unlawful arrest and...
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