Estate of Adriano Roman, Jr. v. City of Newark
914 F.3d 789
| 3rd Cir. | 2019Background
- Newark police entered and searched an apartment without a warrant, handcuffed occupants, found drugs in a common area, and arrested Adriano Roman; the state court suppressed the evidence and the charges were dismissed.
- Roman sued under 42 U.S.C. § 1983 and state law against the City of Newark and individual officers, alleging a municipal custom/policy of unconstitutional searches/arrests and failures to train, supervise, and discipline.
- The District Court dismissed all claims for failure to plead adequately and for procedural noncompliance (N.J. Tort Claims Act), granting leave to amend; Roman amended but omitted tort counts.
- On appeal, the Third Circuit considered the amended complaint plus documents before the District Court (Star-Ledger article, DOJ press release, and the DOJ-Newark consent decree attached to defendants’ motion) but declined to consider a DOJ report not presented below.
- The Court held Roman adequately pleaded municipal liability against Newark (custom and failure-to-train/supervise/discipline) given the consent decree and other materials, but affirmed dismissal of state-law false imprisonment and malicious prosecution claims as pleaded and rejected preclusion defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability (Monell) for warrantless searches/false arrests | Roman alleged a pattern or practice of constitutional violations, inadequate training/supervision/discipline, and linked the DOJ consent decree and press coverage to those practices | Defendants argued the complaint failed to plead a policy/custom and that the consent decree and other documents do not reference the conduct alleged or could not be considered | Court: Roman plausibly alleged a municipal custom of warrantless/nonconsensual searches and failure to train/supervise/discipline; vacated dismissal and remanded on municipal liability |
| Failure-to-train / deliberate indifference | Training was inadequate (officers unduly lacking Fourth Amendment training); DOJ consent decree and press article show systemic deficiencies and lack of discipline | Defendants said consent decree doesn’t prove prior inadequate training or deliberate indifference; District Court found pleading insufficient | Court: Allegations plus consent decree and press materials permit plausible inference of deliberate indifference; claim survives motion to dismiss |
| False imprisonment and malicious prosecution — characterization and procedural compliance | Roman argued claims were federal §1983 claims | Defendants said they were state tort claims and, in any event, Roman failed to comply with the NJ Tort Claims Act notice requirements | Court: Claims were pled as state-law torts (and were omitted from amended complaint); dismissal on Tort Claims Act grounds was on the merits and is affirmed |
| Preclusion doctrines (res judicata / collateral estoppel / judicial estoppel) | Not directly asserted by Roman on merits | Defendants argued prior state criminal proceeding and suppression ruling, or Roman’s prior statements, preclude civil claims | Court: Rejected preclusion/judicial estoppel defenses — prior criminal process did not bar §1983 claims; suppression hearing did not decide the factual issues the defendants invoked |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (municipal liability requires a policy or custom causing the constitutional violation)
- City of Canton v. Harris, 489 U.S. 378 (municipal failure-to-train actionable only for deliberate indifference)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards — courts need not accept legal conclusions)
- Heck v. Humphrey, 512 U.S. 477 (limits on civil suits that would imply invalidity of ongoing criminal judgment)
- Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308 (court may consider documents incorporated by reference or of which it may take judicial notice on motion to dismiss)
- Bielevicz v. Dubinon, 915 F.2d 845 (3d Cir.) (municipal custom proved by persistent practices and notice)
- Doe v. Luzerne County, 660 F.3d 169 (3d Cir.) (elements for deliberate indifference in failure-to-train claims)
- Baraka v. McGreevey, 481 F.3d 187 (3d Cir.) (courts need not accept unwarranted inferences or legal conclusions at pleading stage)