Amey v. Hamilton County
3:18-cv-00276
E.D. Tenn.Jul 2, 2019Background
- On July 6, 2017, Amey alleges he was approached by police at a Staybridge Suites parking lot, thrown to the ground, and while restrained was attacked by a police dog, sustaining leg injuries treated at an emergency room.
- Amey sued under 42 U.S.C. § 1983 naming Hamilton County, Officer Mark Saintlouis, an officer named Duko, and “unknown police/agents,” asserting the dog bite was excessive force.
- The complaint is pro se and the court screened it pursuant to the Prison Litigation Reform Act (28 U.S.C. §§ 1915(e)(2)(B) and 1915A).
- The complaint lacked specific factual allegations tying Saintlouis, Duko, or the unknown officers to the alleged conduct; they appear only in the caption.
- Amey did not allege any official policy or custom of Hamilton County that caused the injury (no Monell theory pleaded).
- The district court concluded the complaint failed to state a § 1983 claim and dismissed the action under the PLRA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether named individual officers were adequately alleged to have participated in the wrongdoing | Amey alleges he was bitten by a police dog during arrest (implying officers were responsible) | No specific factual allegations identify Saintlouis, Duko, or unknown agents as involved or aware of the conduct | Dismissed for failure to plead specific conduct by each defendant; naming without allegations is insufficient |
| Whether supervisory liability against Saintlouis is permissible | Amey appears to assert liability based on Saintlouis being the lead officer | Defendants argue supervisory/respondeat superior liability is not available under § 1983 | Court held supervisory liability alone is insufficient; claims against Saintlouis dismissed |
| Whether claims against officers in official capacity can proceed against Hamilton County | Amey sued officers in official capacities and named Hamilton County | Defendants note official-capacity suits are effectively against the county | Court dismissed redundant official-capacity claims and treated county as the proper municipal defendant |
| Whether Hamilton County is liable under Monell without a policy or custom alleged | Amey seeks relief against Hamilton County for the alleged constitutional violation | County argues no policy/custom alleged to causally link county to the injury | Court held Amey failed to plead a Monell claim; county dismissed |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plaintiff must plead each government official’s own unconstitutional conduct)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim to survive screening)
- Haines v. Kerner, 404 U.S. 519 (1972) (courts construe pro se pleadings liberally)
- Monell v. Dept. of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipal liability requires an unconstitutional policy or custom)
- Braley v. City of Pontiac, 906 F.2d 220 (6th Cir. 1990) (§ 1983 provides remedy for deprivation of federal rights by state actors)