Lyles v. Hughes
2013 U.S. Dist. LEXIS 107991
D.D.C.2013Background
- Plaintiff Pamela Lyles alleges she was unlawfully evicted from her D.C. apartment on April 20, 2012; during the eviction five deputy U.S. Marshals entered, handcuffed her, she was allegedly knocked unconscious, and later hospitalized with a seizure.
- Disputes with landlord D.A. Hubbard arose over housing conditions, a closed laundry room, and rent; plaintiff alleges Hubbard schemed to evict her and enlisted Marshals to carry out the eviction.
- Plaintiff sued multiple defendants: individual landlords (Hubbard, Hunt), corporate owners/management (Park Ainger Apartments, Hubbard Enterprises), and five deputy U.S. Marshals (M. Hughes, Tyler, Hunt, Shanks, Alford), asserting § 1983 claims (Fourth and Fifth Amendment), conspiracy, and common-law torts (negligence, battery, assault, conversion).
- The Court screened the pro se complaint under Rule 12(b)(6) and § 1915(e)(2)(B)(ii), accepting well-pleaded facts and rejecting conclusory allegations per Twombly/Iqbal standards.
- The Court dismissed all § 1983 claims against the private landlord/management defendants for failure to plead state action; it also dismissed without prejudice common-law tort claims against those private defendants for lack of subject-matter (diversity) jurisdiction.
- The Court allowed plaintiff’s constitutional and common-law claims to proceed against the five identified deputy U.S. Marshals, denied (without prejudice) plaintiff’s motion to have Marshals serve the complaint, and ordered an amended complaint consistent with Rule 10.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hubbard, Hunt, and the corporate defendants are state actors under § 1983 | Lyles alleges they conspired with U.S. Marshals and participated in an on‑the‑spot eviction that deprived her constitutional rights | Defendants are private actors; no factual allegations show state coercion, encouragement, or joint activity with government | Dismissed: plaintiff failed to allege state action; § 1983 claims against these private defendants dismissed |
| Sufficiency of conspiracy allegations (civil conspiracy / § 1985) | Lyles alleges Hubbard and Marshals conspired to evict her illegally | Defendants note allegations are vague, conclusory, and lack class‑based animus (for § 1985) or plausible agreement and overt acts | Dismissed: conspiracy allegations are conclusory and fail Iqbal/Twombly pleading standard |
| Subject‑matter jurisdiction over common‑law tort claims against private defendants | Lyles asserts battery, assault, negligence, conversion, etc. against Hubbard, Hunt, and the corporate entities | Defendants argue federal jurisdiction depends on surviving federal claims or diversity; parties share D.C. citizenship so diversity is lacking | Dismissed without prejudice: no federal question survives; diversity jurisdiction absent; common‑law claims against private defendants dismissed for lack of jurisdiction |
| Service and case‑management as to deputy U.S. Marshals | Lyles asked Marshals to serve the complaint on defendants (or sought service via Marshals) | Court requires an adequate, complete complaint and proper pleadings before directing service | Denied without prejudice: amended complaint ordered; if adequate, Clerk will issue summonses and effect service on the Marshals |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard for complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (conclusory allegations insufficient under Rule 8)
- Brentwood Acad. v. Tennessee Secondary Sch. Athletic Ass'n, 531 U.S. 288 (tests for when private conduct is attributable to the State)
- Owen Equip. & Erection Co. v. Kroger, 437 U.S. 365 (requirement that diversity jurisdiction requires complete diversity)
- Garay v. Liriano, 839 F. Supp. 2d 138 (dismissing § 1983 claim against private property manager not a state actor)
- Amiri v. Gelman Management Co., 734 F. Supp. 2d 1 (dismissing constitutional claims against private management absent state action)
- Hajjar‑Nejad v. George Washington Univ., 873 F. Supp. 2d 1 (denying amendment to assert § 1983 claims where private actor not shown to be a state actor)