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3:12-cv-01032
M.D. Tenn.
Oct 29, 2012
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Background

  • Dodson, proceeding pro se, filed a § 1983 complaint against Williamson County Sheriff Jeff Long, Deputy Stephen Shaver, and Patti Walton.
  • Plaintiff alleges he was stopped on Feb. 22, 2012, and subjected to a blood draw by Shaver and others without permission.
  • Plaintiff contends the blood draw amounted to excessive force, due process violation, and an unreasonable search.
  • Court conducts initial screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A and applies Iqbal/Twombly standards.
  • Plaintiff seeks monetary damages against all defendants in their individual and official capacities.
  • Court dismisses some claims as to Long and Walton and allows a colorable Fourth Amendment claim against Shaver to proceed.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Long and Walton can be liable under § 1983 Long/Walton supervisory liability; personal involvement alleged via supervision. No personal involvement or policy; no state-actor basis for Walton; official-capacity claims fail absent policy. Dismissed against Long and Walton in all capacities.
Whether Shaver's conduct violated the Fourth Amendment Blood draw without consent/without warrant constituted unreasonable search/force. Argues no actionable Fourth Amendment violation under the pleaded facts. Colorable Fourth Amendment claim against Shaver; proceeds.
Whether Heck v. Humphrey precludes any damages Arrest-related claims unresolved; damages barred if underlying conviction invalid. Heck may bar claims tied to unlawfulness affecting conviction/sentence. Not dismissed on Heck at this stage; potential later applicability depending on criminal case status.

Key Cases Cited

  • Ashcroft v. Iqbal, 556 U.S. 662 (S. Ct. 2009) (plausibility standard for § 1983 claims)
  • Twombly, 550 U.S. 544 (S. Ct. 2007) (feels-for-plausibility pleading standard)
  • Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (Iqbal/Twombly govern dismissal for failure to state a claim)
  • McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997) (initial screening standards for § 1915)
  • Graham v. Connor, 490 U.S. 386 (S. Ct. 1989) (pretrial excessive force standard under Due Process)
  • Schmerber v. California, 384 U.S. 757 (S. Ct. 1966) (Fourth Amendment governs blood tests; requires justification)
  • Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (S. Ct. 1978) (municipal liability requires policy or custom)
  • Heck v. Humphrey, 512 U.S. 477 (S. Ct. 1994) (damagesBar for claims arising from unconstitutional conviction/sentence)
  • Wolfe v. Perry, 412 F.3d 707 (6th Cir. 2005) (pre-conviction Heck applicability where charges pending)
  • Deaton v. Montgomery Cnty., 989 F.2d 885 (6th Cir. 1993) (municipal liability requirements for policy or custom)
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Case Details

Case Name: Dodson v. Long
Court Name: District Court, M.D. Tennessee
Date Published: Oct 29, 2012
Citation: 3:12-cv-01032
Docket Number: 3:12-cv-01032
Court Abbreviation: M.D. Tenn.
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    Dodson v. Long, 3:12-cv-01032