Hill v. Town of Valley Brook
| Decision Date | 31 March 2022 |
| Docket Number | Case No. CIV-21-00097-PRW |
| Parties | Kimiesha HILL, Jason Garnett, and Kiara McCorkle, on behalf of themselves and all others similarly situated, Plaintiffs, v. TOWN OF VALLEY BROOK, Valley Brook Municipal Court, Lewis Nieman, Mayor of Valley Brook in his official capacity, Stephen Haynes, Municipal Judge, individually and in his official capacity, Michael Stamp, Chief of Valley Brook Police Department, in his official capacity, and Valley Brook Police Department, Defendants. |
| Court | U.S. District Court — Western District of Oklahoma |
Woodrow K. Glass, Jonathan M. Irwin, Ward & Glass LLP, Norman, OK, Arthur Ago, Tianna J. Mays, Lawyers’ Committee for Civil Rights Under Law, Washington, DC, Izabella Babchinetskaya, Pro Hac Vice, Lisa B. Swaminathan, Pro Hac Vice, Jason A. Leckerman, Laura Gavin, Ballard Spahr LLP, Philadelphia, PA, for Plaintiffs.
Andrew W. Lester, Anthony J. Ferate, Courtney Jo Davis Powell, Shannon F. Davies, Spencer Fane LLP, Oklahoma City, OK, for Defendants Town of Valley Brook, Lewis Nieman, Stephen Haynes, Michael Stamp.
Before the Court is Defendants’ Motion to Dismiss (Dkt. 7), Plaintiffs’ Response in Opposition (Dkt. 8), and Defendants’ Reply (Dkt. 15). For the reasons below, the Motion to Dismiss is GRANTED IN PART and DENIED IN PART .
The Town of Valley Brook is a small municipality situated within the Oklahoma City metropolitan area. In 2020, the three Plaintiffs—Kimiesha Hill, Jason Garnett, and Kiara McCorkle—were stopped by Valley Brook police officers for minor traffic offenses. Additionally, the officers searched Ms. Hill and Ms. McCorkle's vehicles despite lacking consent or probable cause. Following the stop and search, the officers took each Plaintiff to the Valley Brook police station, where they demanded immediate payment of hundreds or thousands of dollars in fines. The officers did not explain to any of the Plaintiffs what the fines were for or provide a breakdown of the costs. After determining that Plaintiffs could not immediately pay these fines, Plaintiffs were placed in Valley Brook's prison cell and instructed to call family, friends, or bail bondsmen to raise the money necessary to cover the fines. When this failed, the Valley Brook officers booked each Plaintiff into the Oklahoma County jail. At no point were any of the Plaintiffs advised of their right to counsel, offered counsel, or appointed counsel. Ms. McCorkle remained in jail for four day, Ms. Hill for five days, and Mr. Garnett for one week.
After waiting in the county jail for up to a week, Plaintiffs appeared before Municipal Judge Stephen Haynes. Judge Haynes informed the Plaintiffs that if they pleaded guilty or no contest to the traffic offenses, they would be required to immediately pay all fines in full or else would be sent back to jail. And while a "time payment application" requesting a periodic payment schedule for indigency existed, Judge Haynes preemptively told Plaintiffs that he would deny all such applications. Plaintiffs were still not advised of their right to counsel or appointed counsel. Each Plaintiff pleaded guilty or no contest to the municipal traffic offenses and Judge Haynes ordered each Plaintiff to pay hundreds or thousands of dollars of fines in full. When they could not pay immediately, Judge Haynes ordered each Plaintiff be detained and ordered them to again call family and friends to raise money. At no point did Judge Haynes conduct a financial indigency hearing2 or consider the time payment applications submitted by Ms. Hill and Mr. Garnett. Each Plaintiff was again jailed—Ms. McCorkle for twelve hours, Ms. Hill for four days, and Mr. Garnett for five days. Both Ms. McCorkle and Ms. Hill lost their jobs while imprisoned. Ms. McCorkle ultimately borrowed money from family to pay her fines and gain release, while Ms. Hill and Mr. Garnett were released after spending enough time in jail that a "daily credit" canceled out their fines. However, months later, each Plaintiff received notices that they still owe hundreds of dollars of fines.
Plaintiffs sued Defendants in Oklahoma County District Court, raising seven separate claims: (1) imprisonment for failure to pay a fine, in violation of the Fourteenth Amendment, (2) failure to provide an opportunity to be heard prior to detention, in violation of the Fourteenth Amendment, (3) denial of due process, in violation of Article 2 of the Oklahoma Constitution, (4) indefinite incarceration without a hearing, in violation of the Fourteenth Amendment, (5) excessive and arbitrary fines, in violation of the Eighth Amendment, (6) imprisonment without providing right to counsel or receiving a knowing and voluntary waiver of counsel, in violation of the Sixth Amendment, and (7) unreasonable searches, in violation of the Fourth Amendment. Plaintiffs proposed to certify four separate classes for potential class action and sought declaratory relief, injunctive relief, damages for injuries suffered, vacatur of outstanding fines, and attorney's fees.
Invoking federal-question jurisdiction and supplemental jurisdiction, Defendants removed the case to this Court. Now, pursuant to Rule 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure, Defendants seek to dismiss the action in its entirety.
When reviewing a Rule 12(b)(6) motion to dismiss, all well-pleaded allegations in the complaint must be accepted as true and viewed "in the light most favorable to the plaintiff."3 While a complaint need not recite "detailed factual allegations," "a plaintiff's obligation to provide the grounds of [her] entitle[ment] to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do."4 The pleaded facts must thus be sufficient to establish that the claim is plausible.5 In considering whether a plausible claim has been made, the Court must "liberally construe the pleadings and make all reasonable inferences in favor of the non-moving party."6 However, when considering a Rule 12(b)(6) motion to dismiss, the Court also examines whether the claim fails as a matter of law despite sufficiently detailed factual allegations. Thus, the Court "may grant judgment as a matter of law under Federal Rule of Civil Procedure 12(b)(6) on the basis of an affirmative defense ... when the law compels that result."7
While Rule 12(b)(6) motions challenge the legal sufficiency of a claim, Rule 12(b)(1) motions challenge whether the Court even has jurisdiction over the action. Rule 12(b)(1) motions generally take one of two forms, either "a facial attack on the sufficiency of the complaint's allegations as to subject matter jurisdiction," or "a challenge to the actual facts upon which subject matter jurisdiction is based."8 The legal test applied depends on which type of challenge the movant asserts. When the 12(b)(1) challenge is a facial attack, the Court confines itself to review of the complaint and accepts all allegations as true—much like 12(b)(6) review.9 When the (12)(b)(1) challenge is a factual attack, the Court must "resolve [the] disputed facts" and has "wide discretion to allow affidavits, other documents, [or] a limited evidentiary hearing" to do so.10
Relying primarily on an assortment of abstention and immunity doctrines, Defendants advance eight arguments in support of their motion to dismiss. The Court addresses each in turn.
Defendants first argues that Ms. McCorkle and Mr. Garnett are barred from seeking redress in federal court by the Rooker-Feldman doctrine. Setting aside the impropriety of permitting Defendants to remove a case to federal court and then dismiss the case for the federal court being the wrong venue, Rooker-Feldman does not bar this Court's exercise of jurisdiction since Plaintiffs’ claims and relief do not challenge or affect the validity of the underlying traffic violation judgments.
The Rooker-Feldman doctrine precludes "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."11 Thus, the Rooker-Feldman doctrine prevents "a party losing in state court ... from seeking what in substance would be appellate review of [a] state judgment in a United States district court, based on the losing party's claim that the state judgment itself violates the loser's federal rights."12 This extends to both "claims actually decided by a state court, and claims inextricably intertwined with a prior state-court judgment."13 However, notably exempted are "challenge[s to] state procedures for enforcement of a judgment, where consideration of the underlying state-court decision is not required."14
Here, Defendants argue that Ms. McCorkle and Mr. Garnett seek to effectively review and invalidate the state court judgments from the Valley Brook municipal court. However, a closer examination of the pleadings reveals that the Plaintiffs do not contest their guilt or challenge the validity of the municipal traffic convictions. Plaintiffs challenge various alleged unconstitutional actions—such as unreasonable searches unrelated to the offense of conviction—that have no bearing on the validity of the state's traffic violation judgments and seek injunctive relief to stop Defendants from continuing such constitutional violations. And Plaintiffs challenge various alleged unconstitutional actions—such as imprisonment without due process for failure to pay the fines associated with the state's traffic violation judgments—that address the state court's post-judgment collection procedures, rather than the state judgment itself. Even with "[v]acatur of all outstanding fines," if Plaintiffs’ pleadings are favorably construed, they are challenging not the fines assessed by the state court, but rather the arbitrary fines Valley...
To continue reading
Request your trial