Watkins v. City of St. Louis
| Decision Date | 28 September 2022 |
| Docket Number | 4:21-cv-01344-SEP |
| Parties | SARAH WATKINS, Plaintiff, v. CITY OF ST. LOUIS, et al., Defendants. |
| Court | U.S. District Court — Eastern District of Missouri |
Before the Court are motions to dismiss filed by Defendant City of St. Louis, Doc. 7; Defendants Metcalf, Thompson, Baker Colombo, and Morris (collectively, the “Individual Defendants”), Doc. 11; and Defendants Baker, Colombo and Morris, Doc. 38. For the reasons set forth below, the motions filed by the City and the Individual Defendants are granted, and the motion filed by Baker, Colombo, and Morris is denied as moot.
Plaintiff Sarah Watkins brings this action under 42 U.S.C. § 1983 against the City of St. Louis and St. Louis International Airport Police officers Andrew Metcalf, Bryant Morris, Darryl Baker, Justin Colombo, and Anthony Thompson, for violation of her rights protected by the Fourth, Eighth, and Fourteenth Amendments to the United States Constitution.[1] See Doc 1 ¶¶ 26-47.
At 9:00 PM on December 24, 2016, Plaintiff, a 230-pound, 29-year-old female, was driving near the St. Louis Lambert International Airport when Officer Metcalf stopped her vehicle for an alleged traffic violation. Doc. 1 ¶¶ 15-16. Metcalf informed the Airport Police Department of the stop and Officers Morris, Baker, Colombo, and Thompson arrived soon after to assist. Id. ¶ 17.
Due to the order of the allegations and the Complaint's lack of detail about each party's alleged actions, the chronology of events is not clear. At some point, Metcalf ordered Plaintiff to exit her vehicle and then handcuffed her at the rear of her vehicle. Id. ¶¶ 19-20. Apparently believing that Plaintiff was resisting arrest, id. ¶ 23, Metcalf “yelled” at Plaintiff and “forced her into the front of her vehicle.” Id. ¶ 20. At some point after forcing Plaintiff into her vehicle, Metcalf attempted to force Plaintiff into his own vehicle. Id. ¶ 20. As that happened, “Defendant Officers sprayed her with pepper spray and repeatedly hit her on the leg with a baton.” Id. ¶ 20. “Defendant Officers continued to pepper spray and hit [her] while she was restrained and pinned in the front seat of Officer Metcalf's car ....” Id. ¶ 21.
Apparently at some later point, one, several, or all of the officers “pepper sprayed and hit [Plaintiff] while she was on the ground,” and while one, several, or all of the officers “were present and available to maneuver and otherwise secure [her] cooperation.” Id. ¶ 22. No allegation imputes any specific action to any Individual Defendant other than Officer Metcalf. No allegation describes Plaintiff's demeanor or conduct during the incident.
At some point, having “secured [Plaintiff's] cooperation,” the officers transported Plaintiff to the Airport police station and offered to transport her to the “emergency room” for treatment. Id. ¶ 24. Plaintiff apparently declined their offer and was instead treated at “urgent care” for “lacerations and bruising to her leg,” as well as “pain and injuries caused to her face and body.” Id. ¶ 25.
Plaintiff's Complaint sets forth two counts. In Count I, Plaintiff seeks monetary damages against the Individual Defendants in their individual and official capacities under 42 U.S.C. § 1983, based on allegations that they unlawfully seized, assaulted, and brutalized her in violation of her rights secured by the Fourth, Eighth, and Fourteenth Amendments to the United States Constitution. In Count II, Plaintiff seeks monetary damages against the City of St. Louis under 42 U.S.C. § 1983, on the basis that the City had a policy or custom, or it failed to train or supervise its officers, which caused Plaintiff to be deprived of her constitutional rights by the Individual Defendants as described above.
On January 25, 2022, the City filed a motion to dismiss Count II pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. Doc. 7. That motion is fully briefed.
On February 16, 2022, all six Individual Defendants filed a joint motion to dismiss Count I pursuant to Rules 12(b)(5) and (6) for insufficient service of process and failure to state a claim, respectively. Doc. 11. On March 18th, Plaintiff filed her memorandum in opposition to that motion, which effectively conceded the Individual Defendants' ineffective service of process argument but argued that the Court should grant her an extension of time to effectuate service. Doc. 22 at 4-7. The Court informed Plaintiff that any request for an extension of time must be made in its own motion, and on May 23rd, Plaintiff filed a consent motion for extension of time to effectuate service of process. Doc. 28. The Court granted that motion on May 24th and gave Plaintiff additional time to properly serve the Individual Defendants. Doc. 29.
On June 28th, Defendants Morris, Baker, and Colombo filed a second motion to dismiss. Doc. 38. That second motion raises a new Rule 12(b)(5) argument, but neither party made any alterations to the Rule 12(b)(6) arguments made in the briefing of the first motion to dismiss. See Docs. 39, 41. Accordingly, as to the June 28th Morris, Baker, and Colombo motion to dismiss, the Court addresses only the argument for dismissal under Rule 12(b)(5).
The purpose of a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) is to test the legal sufficiency of a complaint. When considering a Rule 12(b)(6) motion, a court assumes the factual allegations of a complaint are true, Neitzke, 490 U.S. at 326-27, and draws all reasonable inferences in the non-movant's favor, Braden v. Wal-Mart Stores, Inc., 588 F.3d 585, 595 (8th Cir. 2009) (citation omitted).
Federal Rule of Civil Procedure 8(a)(2) provides that a complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” In Bell Atlantic Corporation v. Twombly, the Supreme Court explained that Rule 8(a)(2) requires that a complaint contain ”more than labels and conclusions,” and that “a formulaic recitation of the elements of a cause of action will not do.” 550 U.S. 544, 555 (2007); accord Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). In Ashcroft v. Iqbal, the Supreme Court reiterated that Rule 8 “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation,” and that “naked assertions devoid of further factual enhancement” will not suffice. 556 U.S. at 678 (quoting Twombly, 550 at 557) (quotation marks omitted).
To survive a motion to dismiss, a complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.'” Id. at 678 (quoting Twombly, 550 U.S. at 570). The issue in considering such a motion is not whether the plaintiff has proven the claim or whether the plaintiff will ultimately prevail, but whether the plaintiff is entitled to engage in the discovery necessary to support the claim. See Twombly, 550 U.S. at 556.
The Individual Defendants move to dismiss Count I under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief may be granted. Doc. 11. Count I brings § 1983 claims against the Individual Defendants in their individual and official capacities for violating Plaintiff's rights secured by the Fourth, Eighth, and Fourteenth Amendments to the United States Constitution. Doc. 1 ¶¶ 26-35. As set forth below, all claims in Count I will be dismissed.
A. Plaintiff's official-capacity claims against the Individual Defendants are redundant of her claim against the City.[3]
“A core tenet of 42 U.S.C. § 1983 jurisprudence is that an official-capacity suit against an individual is really a suit against that official's government entity.” Banks v. Slay, 875 F.3d 876, 878 (8th Cir. 2017). “Thus, the real party in interest in an official-capacity suit is not the named official, but the government entity.” Stockley v. Joyce, 2019 WL 630049, at *26 (E.D. Mo. Feb. 14, 2019) (citing Hafer v. Melo, 502 U.S. 21, 25 (1991)). “It is proper for a court to dismiss a claim against a government officer in his official capacity as duplicative or redundant if the claims are also asserted against the officer's governmental employer.” Caruso v. City of St. Louis, 2016 WL 6563472, at *1 (E.D. Mo. Nov. 4, 2016) (citing Veatch v. Bartels Lutheran Home, 627 F.3d 1254, 1257 (8th Cir. 2010)). Because Plaintiff has asserted a claim based on the same occurrence against both the Individual Defendants and their governmental employer, the City of St. Louis, her redundant official-capacity claims against the Individual Defendants are subject to dismissal.
B. Plaintiffs' individual-capacity claims also fail.
The Individual Defendants argue that Count I should be dismissed because Plaintiff fails to state a claim for conspiracy under 42 U.S.C. § 1985, see Doc. 12 at 12-13; Plaintiff fails to state a claim under the Eighth and Fourteenth Amendments, see id. at 11-12; and the Individual Defendants are entitled to qualified immunity against Plaintiff's Fourth Amendment claim, see Doc. 12 at 7-11. The Court considers each argument in turn.
The Complaint states that the Individual Defendants are being sued “under 42 U.S.C. §§ 1983, 1985, and 1988,” and that Plaintiff's “actions arise under 42 U.S.C. §§ 1983, 1985, and 1988.” Doc. 1 ¶¶ 2, 10. 42 U.S.C. § 1985(3) does allow Plaintiff to sue state actors for conspiracy to deprive her of her federally protected civil rights. Although the Complaint does not expressly set forth a...
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