Estate of William Carver v. Mattingly, 3:24-cv-00582

The Estate of William Carver alleges that Carver was wrongfully shot and killed by his employer, Todd Mattingly, or others acting on Todd’s behalf in Marion County, Kentucky.
Robert Mattingly, the County Coroner and Todd’s relative, is accused of refusing to autopsy Carver, ruling the death a suicide, and ordering Carver’s cremation against his family's wishes.
The Estate brings wrongful death and negligence claims against Todd and several claims against Robert, including § 1983 federal due process claims and state law claims.
Robert moved to dismiss all claims against him; Todd filed a motion to dismiss, and the Estate sought various interim relief (TRO, hearing, sanctions).
The Court addresses the sufficiency of the Estate’s § 1983 claims and whether to retain jurisdiction over state law claims after disposing of the federal claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Fifth Amendment to Robert	Robert violated Estate's Fifth Amendment rights by improperly cremating Carver and acting in bad faith	Fifth Amendment only limits federal, not state, actors	Dismissed: Fifth Amendment inapplicable to state officials
Sufficiency of Official Capacity § 1983 Claim	Robert (as coroner) violated Carver’s constitutional rights in his official capacity	Official capacity claim = claim against Marion County; no policy or custom adequately alleged	Dismissed: Complaint does not meet Monell requirements
Viability of § 1983 claim for post-mortem conduct	Estate may sue for constitutional violations arising from coroner’s post-mortem conduct	§ 1983 cause of action cannot be based on post-death conduct	Dismissed: No § 1983 claim for posthumous rights
Court’s exercise of supplemental jurisdiction	Federal court should retain state law negligence/conversion claims	Dismiss state law claims if federal claims dismissed	Declined: Supplemental jurisdiction not exercised; state law claims dismissed

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (establishes plausibility standard for 12(b)(6) motion to dismiss)
Ashcroft v. Iqbal, 556 U.S. 662 (clarifies pleading requirements for stating a plausible claim)
Monell v. Dep’t of Soc. Serv. of City of N.Y., 436 U.S. 658 (municipal liability under § 1983 requires policy or custom)
Ky. v. Graham, 473 U.S. 159 (official-capacity suits equate to suits against the governmental entity)
Garner v. Memphis Police Dep’t, 8 F.3d 358 (plaintiff must link injury to specific policy for municipal liability)
Claybrook v. Birchwell, 199 F.3d 350 (§ 1983 claim is personal to deceased; no claim for family members’ distress)