Holloran v. Duncan
92 F. Supp. 3d 774
W.D. Tenn.2015Background
- On June 22–23, 2012 Benton County deputies and Sheriff Tony King responded to a dispatch reporting possible underage drinking at the Holloran family farm; deputies entered the property and encountered a large party.
- Officers encountered underage persons drinking, some guests fled into woods, and deputies gathered over 100 attendees; Sheriff King ordered arrests of everyone at the scene.
- Numerous attendees were transported to the county jail, processed, held in crowded conditions, and later released; several plaintiffs allege force and mistreatment during arrest and detention.
- Plaintiffs sued under 42 U.S.C. § 1983 (Fourth and Fourteenth Amendments) and state tort and constitutional claims against the County, Sheriff King, multiple deputies, and unnamed John Doe officers.
- The court considered motions for summary judgment: (1) Moving Plaintiffs’ partial SJ seeking municipal liability and failure-to-intervene rulings; (2) Deputy Defendants’ SJ (qualified immunity); and (3) County Defendants’ partial SJ. The court granted, denied, or dismissed various claims as summarized below.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability (County via Sheriff King) | King’s orders and decisions caused constitutional deprivations; County is liable for policymaker acts | County: disputes underlying constitutional violations | Granted in part — King was the policymaker; municipal liability may attach if King liable |
| Warrantless entry onto property | Plaintiffs: locked gate/No Trespassing bars entry without warrant | Defendants: entry lawful under open-fields/knock-and-talk; investigation of underage drinking | Entry lawful under open-fields doctrine; summary judgment for defendants on entry claims |
| Initial detention/roundup at property (Terry stop) | Plaintiffs: mass detention unreasonable | Defendants: reasonable suspicion existed (dispatch + observed underage drinking + flight); detention proportionate | Initial detention reasonable and not excessive; summary judgment for defendants on detention claims |
| Excessive force and failure to intervene | Plaintiffs: Sheriff used excessive force (esp. on Holloran Jr.); deputies failed to stop unconstitutional arrests/force | Defendants: many deputies not present or lacked opportunity; qualified immunity applies | Excessive force claims dismissed for Holloran Sr. and Roden; Holloran Jr. claim proceeds; jury issues remain as to some deputy liability; failure-to-intervene viable against some deputies (Duncan re: Holloran Jr.; other failure-to-intervene claims survive fact-question) |
| Malicious prosecution | Plaintiffs: prosecutions lacked probable cause and were pursued by deputies | Defendants: no evidence deputies made/procured prosecution decisions | Malicious prosecution dismissed for lack of evidence proving deputies made/influenced prosecution decision |
| Individual arrests of Moving Plaintiffs (probable cause) | Plaintiffs seek summary judgment that arrests were unlawful | Defendants assert probable cause for some arrests and that King made arrest decisions | Moving Plaintiffs’ SJ denied; probable-cause and individual participation create jury issues; qualified immunity not resolved at summary judgment |
| Williams’s unlawful arrest/false imprisonment (Heck bar) | Williams: conviction not a bar because statute technical or not criminal | Defendants: conviction/judicial diversion precludes federal claim under Heck | Summary judgment for defendants; Williams pleaded guilty and received diversion, Heck bars federal claim |
| Conditions of confinement / medical care | Plaintiffs: denial of necessities and medical care at jail | Defendants: no evidence of serious medical need or deliberate indifference | Claims dismissed for lack of evidence showing serious medical need or deliberate indifference |
| State-law claims (GTLA and Tennessee Constitution) | Plaintiffs pursue state tort and constitutional claims | Defendants: GTLA governs and state courts preferred; no private damages remedy under TN constitution | Federal court declines supplemental jurisdiction over GTLA claims (dismissed without prejudice); Tennessee constitutional claims dismissed (no private right of action) |
Key Cases Cited
- Oliver v. United States, 466 U.S. 170 (open-fields doctrine permits warrantless entry into open fields)
- Hester v. United States, 265 U.S. 57 (common-law distinction between homes and open fields)
- Katz v. United States, 389 U.S. 347 (reasonable expectation of privacy test)
- Terry v. Ohio, 392 U.S. 1 (permissible investigative stops under Fourth Amendment)
- Navarette v. California, 134 S. Ct. 1683 (reasonable suspicion standard for investigatory stops)
- Connick v. Thompson, 563 U.S. 51 (municipal liability requires action pursuant to official policy)
- Heck v. Humphrey, 512 U.S. 477 (bar on § 1983 claims that would imply invalidity of conviction)
- Burgess v. Fischer, 735 F.3d 462 (Sixth Circuit on single-act municipal liability standard)
- Bruner v. Dunaway, 684 F.2d 422 (Sixth Circuit recognizing liability for failure to intervene)
- Smith v. Ross, 482 F.2d 33 (Sixth Circuit: omissions by officers can create § 1983 liability)