Martinez v. Hudson
| Decision Date | 22 June 2017 |
| Docket Number | Case No.: 2:17-cv-00256-RDP |
| Parties | EDER MARTINEZ, et al., Plaintiffs, v. RONALD W. HUDSON, et al., Defendants. |
| Court | U.S. District Court — Northern District of Alabama |
This case is before the court on Defendants' Motion to Dismiss, or in the Alternative, Motion for Summary Judgment (Doc. # 5) and Plaintiffs' Motion to Strike (Doc. # 9). The parties have briefed the motions, and they are under submission. (Docs. # 8, 11-12). For the reasons explained below, the court concludes that Defendants' motion is due to be granted in part and denied in part. Plaintiffs' motion is due to be denied.
This case arises from Eder Martinez's and Adam Denard's interactions with officers in the Adamsville Police Department following a January 2016 accident. According to the Complaint, on January 26, 2016, a City of Adamsville employee struck Martinez's trailer with another vehicle on Highway 78. (Doc. # 1 at ¶¶ 12-13). Martinez parked on the shoulder of Highway 78 because the accident broke a trailer axle. (Id. at 14). Defendants William McKinney and Ronald Hudson, police officers for the Adamsville Police Department, investigated the accident. (Id. at ¶¶ 7-8, 15-16). Hudson refused to accept an electronic copy of an insurance card from Martinez. (Id. at ¶ 17). McKinney searched for records associated with Martinez's truck and asked him about a discrepancy between his truck, a Ford F-250, and the records that associated the license plate with a Ford F-150. (Id. at ¶ 20). Hudson then accused Martinez of altering the truck's Vehicle Identification Number ("VIN"). (Id. at ¶ 21). Hudson directed Martinez to remove the trailer from the highway shoulder (id. at ¶ 22), and McKinney informed Martinez that the truck would be impounded. (Id. at ¶ 26). Ultimately, Martinez's truck and trailer were towed away from Highway 78 and held at an Adamsville impound lot. (Id. at ¶ 29).
Martinez returned home and picked up his paperwork regarding the truck. (Id. at ¶ 31). After doing so, Martinez and Denard went to the Adamsville Police Department to retrieve the truck and trailer. (Id. at ¶ 32). At the station, Defendant Ira Leniger took Martinez and Denard into custody while he investigated the matter. (Id. at ¶ 33). Officers detained Martinez and Denard in a jail cell for approximately two hours, after which they were released. (Id. at ¶¶ 34-35). Leniger declined to provide Martinez proof that the investigation had occurred and would not disclose what records misidentified his truck as a Ford F-150.1 (Id. at ¶ 36).
Plaintiffs' complaint presents eight separate 42 U.S.C. § 1983 claims. (Id. at ¶¶ 37-84). Plaintiff Martinez alleges that Defendants Hudson and McKinney violated his Fourth Amendment freedom from unreasonable seizure of property when they seized his truck. (Id. at ¶¶ 37-48). Martinez also alleges that Defendants Hudson, McKinney, and Leniger violated his Fourth Amendment freedom from unreasonable seizure when they incarcerated him in the Adamsville City Jail without arguable probable cause to believe he committed a crime. (Id. at ¶¶ 49-66). Likewise, Plaintiff Denard claims that the three Defendants violated his FourthAmendment freedom from unreasonable seizure when they incarcerated him in the Adamsville City Jail without arguable probable cause. (Id. at ¶¶ 67-84).
On February 16, 2016, Plaintiff Martinez signed a release of claims against the City of Adamsville, Samuel Dean Owen, and Alabama Municipal Insurance Company, as well as their agents and servants. (Doc. # 5-2). In exchange for $6,253.29, Martinez agreed to discharge "any and all claims, actions, causes of action, demands, rights, damages, costs, loss of service, expenses and compensation" which "accrue[d] on account of or in any way [grew] out of . . . the accident, casualty, or event which occurred on or about the 26th day of January, 2016, at or near U.S. Highway 78 in Adamsville, Alabama." (Id.) (emphasis in original).
In his affidavit, Plaintiff Martinez avers that he brought a Carfax report, two insurance cards, and a print-out of a "Ford Motor Vehicle VIN on-line search" with him when he returned to the Adamsville Police Department on January 26, 2016. (Doc. # 8-1 at 5). Nevertheless, Defendant Leniger refused to review the documents "and said he didn't have to look at [them]." (Id.). Leniger directed Martinez and Denard to empty their pockets, frisked them, and held them in jail until he completed an investigation. (Id. at 5-6; Doc. # 8-3 at 4-5).
Defendants suggest in the caption of their motion that they seek dismissal of Plaintiffs' claims and summary judgment as an alternative remedy. (See Doc. # 5 at 1). A review of their brief, however, indicates that Defendants primarily seek summary judgment on the meager record presented with their motion. For example, Defendants argue that the court should dismiss Plaintiff Martinez's claims because of a release mentioned nowhere in the complaint. (Doc. # 5-1 at 3-5). And, Defendants argue that the court should grant them qualified immunity because they had arguable probable cause to arrest Plaintiffs, as shown by an evidentiary exhibit attached to the motion. (Id. at 6-7) (citing Doc. # 5-4). Even though this case is in the early stages of litigation, Plaintiffs have agreed to play on the field laid by Defendants and have submitted affidavit and documentary evidence to oppose Defendants' motion. (Docs. # 8, 8-1, 8-2, & 8-3). The court sees no option other than ruling on Defendants' motion as a motion for summary judgment.
Under Federal Rule of Civil Procedure 56(c), summary judgment is proper "if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law." Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). The party asking for summary judgment always bears the initial responsibility of informing the court of the basis for its motion and identifying those portions of the pleadings or filings which it believes demonstrate the absence of a genuine issue of material fact. Id. at 323. Once the moving party has met its burden, Rule 56(c) requires the non-moving party to go beyond the pleadings and -- by pointing to affidavits, or depositions, answers to interrogatories, and/or admissions on file -- designate specific facts showing that there is a genuine issue for trial.Id. at 324.
The substantive law will identify which facts are material and which are irrelevant. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986) ("Anderson"). All reasonable doubts about the facts and all justifiable inferences are resolved in favor of the non-movant. See Allen v. Bd. of Pub. Educ. For Bibb Cty., 495 F.3d 1306, 1314 (11th Cir. 2007); Fitzpatrick v. City of Atlanta, 2 F.3d 1112, 1115 (11th Cir. 1993). A dispute is genuine "if the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Anderson, 477 U.S. at 248. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted. See id. at 249.
When faced with a "properly supported motion for summary judgment, [the nonmoving party] must come forward with specific factual evidence, presenting more than mere allegations." Gargiulo v. G.M. Sales, Inc., 131 F.3d 995, 999 (11th Cir. 1997). As Anderson teaches, under Rule 56(c) a plaintiff may not simply rest on her allegations made in the complaint; instead, as the party bearing the burden of proof at trial, she must come forward with at least some evidence to support each element essential to her case at trial. See Anderson, 477 U.S. at 252. "[A] party opposing a properly supported motion for summary judgment 'may not rest upon the mere allegations or denials of [her] pleading, but . . . must set forth specific facts showing that there is a genuine issue for trial.'" Id. at 248 (citations omitted).
Defendants' motion presents three bases for summary judgment on both Denard's and Martinez's claims: (1) qualified immunity, (2) discretionary-function immunity, and (3) the City of Adamsville's responsibility for damages from actions committed within the line and scope ofDefendants' job duties.3 Additionally, Defendants insist that the court should dismiss Plaintiff Martinez's claims because they fall within the scope of the February 2016 release. The court begins its discussion by determining the effect of the release.
It is well settled than an unambiguous release of claims supported by consideration will be applied "according to the intention of the parties to be judged from what appears within the four corners of the instrument." Conley v. Harry J. Whelchel Co., 410 So. 2d 14, 15 (Ala. 1982). Parol evidence cannot be used to impeach the terms of an unambiguous release. Id.
In Nix v. Henry C. Beck Company, the Alabama Supreme Court interpreted a release discharging all claims that accrued to a party under a construction contract or grew out of that construction contract. 572 So. 2d 1214, 1215-17 (Ala. 1990). Although the parties had entered into the release during a settlement of a breach of contract claim, the Alabama Supreme Court held that the release also discharged a negligence claim arising from asbestos installation because its "unambiguous" language evinced an intent "to prevent the parties from asserting any claim or claims that might arise out of the . . . contract." Id. In response to an argument that the parties had intended to limit the release to contract claims, the Alabama Supreme Court observed that the parties could have expressly omitted other types of claims from the general release. Id. at 1216.
Here, the...
To continue reading
Request your trial