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Melton v. Hunt County

United States District Court, N.D. Texas, Dallas Division

October 8, 2019

HUNT COUNTY, et al., Defendants.


          David C. Godbey United States District Judge.

         This Order addresses Defendants Hunt County's, Hunt County Sheriff's Office's, Randy Meeks's, and Kelly D. Phillips's motions to dismiss [47], [49], [51], [53]. For the reasons stated below, the Court grants the motions.

         I. Origins of the Dispute

         Plaintiff Michael David Melton filed a civil rights action against Hunt County, Hunt County Sheriff's Office, Randy Meeks, and Kelly D. Phillips. Melton claimed he was mistakenly arrested for an assault he did not commit. Phillips, who was a deputy with the Sheriff's Office, arrived at a hospital in Greenville, Texas, to investigate a reported assault. The victim, Richard Griffeth, told Phillips that the assailant was named “Michael Melton.” Phillips began an investigation, generated a written report, and submitted it to the Criminal Investigation Division. Meeks was the Hunt County Sheriff at the time of the investigation. Phillips's report identified “Michael David Melton” as the suspect, but the true assailant was “Michael Glenn Melton.” Hunt County then wrongly arrested and charged Plaintiff Melton, but the County later released him and dropped the charges.

         Melton brought this suit in state court asserting both federal- and state-law causes of action. Melton brought federal claims under 42 U.S.C. § 1983 against Meeks and Phillips in their individual capacities for unlawful arrest and detention in violation of the Fourth and Fifth Amendments. Melton also sued Hunt County and Hunt County Sheriff's Office under section 1983 for municipal liability based on official policy and failure to train. Additionally, Melton asserted state-law claims for civil conspiracy, false imprisonment, intentional infliction of emotional distress, assault and battery, negligence and gross negligence, and negligent hiring, supervision, and training. Then, Defendants removed this action in June 2014.

         The Court granted summary judgment for Meeks on Melton's section 1983 Fourth and Fifth Amendment claims and for Phillips on Melton's section 1983 Fifth Amendment claim. Order 8-9 [21]. The Court reasoned that Melton presented no evidence that Meeks was involved in the investigation and that there was no basis to hold Meeks liable for either of Melton's section 1983 claims. Id. The Court also determined that Melton presented no evidence to hold Phillips liable on Melton's section 1983 Fifth Amendment claim. Id. at 9. The Fifth Circuit then granted summary judgment for Phillips on the remaining section 1983 Fourth Amendment claim. Melton v. Phillips, 875 F.3d 256, 266 (5th Cir. 2017) [27]. The Fifth Circuit concluded that Phillips did not violate a statutory or constitutional right. Id. It determined that Phillips was overall too attenuated to be held liable because Phillips did not prepare, sign, or authorize the incident report. Id. at 261, 265. Additionally, the Fifth Circuit found that Melton failed to show that Phillips violated any clearly established law. Id.

         After these rulings, Melton filed an amended complaint, yet he did not assert any new or different claims. Then, the Court dismissed all state-law claims against Meeks and Phillips [46]. Now, Hunt County seeks to dismiss all federal- and state-law claims. Hunt County Sheriff's Office seeks to dismiss all federal-law claims, and Meeks and Phillips move to dismiss all federal-law claims.

         II. Legal Standard for a Rule 12(b)(6) Motion to Dismiss

         When addressing a Rule 12(b)(6) motion to dismiss, the Court must determine whether the plaintiff has asserted a legally sufficient claim for relief. Blackburn v. City of Marshall, 42 F.3d 925, 931 (5th Cir. 1995). To survive dismissal, a complaint must include “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). To satisfy this standard, a plaintiff must plead factual content “that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A plaintiff must provide “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. The plaintiff's factual allegations “must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Id. (internal citations omitted).

         In ruling on a Rule 12(b)(6) motion, the court generally limits its review to the face of the pleadings, accepting as true all well-pleaded facts and viewing them in the light most favorable to the plaintiff. Spivey v. Robertson, 197 F.3d 772, 774 (5th Cir. 1999). A court does not, however, accept as true “conclusory allegations, unwarranted factual inferences, or legal conclusions.” Ferrer v. Chevron Corp., 484 F.3d 776, 780 (5th Cir. 2007).

         III. The Court Dismisses All Federal and State Claims Against Hunt County

         A. The Court Dismisses All Federal Claims Against Hunt County

         Melton asserts section 1983 claims for municipal liability based on official policy and failure to train. A municipality cannot be liable under section 1983 on the theory of respondeat superior but can be liable when “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., 436 U.S. 658, 690-91 (1978). A municipality cannot be held liable when the underlying employees do not commit a constitutional violation. Self v. City of Mansfield, 369 F.Supp.3d 684, 702 (N.D. Tex. 2019) (Fish, J.); see also City of Los Angeles v. Heller, 475 U.S. 796, 799 (1986).[1] To hold a municipal liable based on its official policy, a plaintiff must show “(1) an official policy (or custom), of which (2) a policy maker can be charged with actual or constructive knowledge, and (3) a constitutional violation whose ‘moving force' is that policy (or custom).” Pineda v. City of Houston, 291 F.3d 325, 328 (5th Cir. 2002) (citing Piotrowski v. City of Houston, 237 F.3d 567, 578 (5th Cir. 2001)).

         Similarly, a failure-to-train claim requires the plaintiff to show “(1) the municipality's training policy or procedure was inadequate; (2) the inadequate training policy was a ‘moving force' in causing violation of the plaintiff's rights; and (3) the municipality was deliberately indifferent in adopting its training policy.” Valle v. City of Houston, 613 F.3d 536, 544 (5th Cir. 2010). ‚ÄúDeliberate indifference is a ...

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