Leonard v. George Washington University Hospital
273 F. Supp. 3d 247
| D.D.C. | 2017Background
- Pro se plaintiff Stephen D. Leonard filed a § 1983 civil-rights complaint (originally in S.D. Fla., transferred to D.D.C.) against GW University Hospital, Georgetown/MedStar, Georgetown University, MPD, D.C., D.C. Animal Shelter (Humane Rescue Alliance), U.S. Capitol Police, and FBI arising from events Apr 30–May 3, 2015.
- Plaintiff alleges he sought ER care for chest/abdominal pain, overheard staff/police discussing his parked truck and dog, left the ER, experienced medical emergencies while driving, and was taken to various hospitals and a mental-health evaluation center.
- A U.S. Capitol Police officer took possession of his truck and the dog (Jasmine); the dog later was placed at the D.C. Animal Shelter and euthanized; plaintiff did not contact the shelter until ~two months later.
- Plaintiff alleges unlawful searches/seizures, denial of medical care, forcible psychiatric detention/injection, a conspiracy among multiple actors, RICO and various federal criminal violations, and seeks monetary damages.
- Defendants moved to dismiss under Rule 12(b)(6); the Court held plaintiff failed to state any federal claim and declined supplemental jurisdiction over local/common-law claims, dismissing the action under 28 U.S.C. § 1915(e).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valid federal civil-rights claims under §§ 1981, 1983, 1985, 1986 | Leonard contends defendants conspired and violated his federal rights (racial and conspiracy-based claims included) | Defendants argue plaintiff pleads no race-based animus, no facts showing state action or municipal policy, and no § 1985 conspiracy allegations | Dismissed: plaintiff fails to plead membership in a protected class or class-based animus; no plausible § 1981/§ 1985/§ 1986 claims stated |
| § 1983 liability against federal actors and private hospitals/uni | Leonard alleges collusion among federal, municipal, and private actors causing constitutional deprivations | § 1983 generally covers state/local actors; federal actors not normally subject; private actors require state action or municipal custom/policy | Dismissed: no facts showing federal actors acted under color of D.C. law or private actors acted pursuant to an unconstitutional policy or joint state action |
| Fourth Amendment unreasonable search/seizure (truck/dog) | Leonard alleges his truck was illegally searched and his dog seized without consent or warrant | Defendants point to community-caretaking and that plaintiff left ER voluntarily; seizure of vehicle/dog occurred during police caretaking/public-safety response | Dismissed: facts do not plausibly allege an unconstitutional search; police action falls within community-caretaking function |
| Fifth Amendment due process (involuntary psychiatric detention/injection; deprivation of property re: dog) | Leonard alleges involuntary admission, forced injection, and that the shelter euthanized his dog without due process | Defendants assert psychiatric hold and medical treatment followed emergency/mental-health procedures; shelter complied with D.C. animal laws and plaintiff received no timely notice only because he was absent | Dismissed: plaintiff fails to show custodial/state-policy deprivation or municipal custom; dog disposal does not show a constitutional violation and criminal statutes cited do not create private causes of action |
| RICO and private enforcement of federal criminal statutes | Leonard cites RICO and many criminal provisions as bases for civil relief | Defendants note RICO predicates are not alleged, and most criminal statutes cited do not create private causes of action | Dismissed: RICO/predicate pattern not plausibly alleged; criminal statutes cited do not imply private civil remedies |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim; courts need not accept conclusory allegations)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires unconstitutional policy or custom)
- DeShaney v. Winnebago County Department of Social Services, 489 U.S. 189 (1989) (no general constitutional duty to protect individuals from private harm absent special relationship)
- Linda R.S. v. Richard D., 410 U.S. 614 (1973) (private citizen lacks judicially cognizable interest in prosecution of another)
- Cady v. Dombrowski, 413 U.S. 433 (1973) (community-caretaking doctrine allows certain warrantless searches/seizures)
- City of Revere v. Massachusetts General Hospital, 463 U.S. 239 (1983) (Eighth Amendment inapplicable absent criminal conviction)
- H.J., Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229 (1989) (RICO requires related predicate acts amounting to or posing a threat of continued criminal activity)
- Griffin v. Breckenridge, 403 U.S. 88 (1971) (§ 1985(3) requires class-based, invidiously discriminatory animus)
- Atherton v. District of Columbia Office of the Mayor, 567 F.3d 672 (D.C. Cir. 2009) (pro se complaints must still plead factual matter permitting plausible claims)