Santiago v. Warminster Township
2010 U.S. App. LEXIS 25414
| 3rd Cir. | 2010Background
- Warminster conducted a May 13, 2006 surround-and-call-out raid on Santiago's home to apprehend a grandson named in an arrest warrant.
- Alpha Team personnel executed the operation; Warminster provided outside personnel/equipment under temporary control.
- Santiago was ordered out at gunpoint, searched, restrained for about 30 minutes, and complained of chest pain during the raid.
- Santiago later suffered a heart attack; a family member and others were treated differently during the search.
- Santiago filed a 1983 claim against Warminster and several officers; the district court dismissed certain claims and this appeal followed.
- The Third Amended Complaint added Supervising Officers (Murphy, Springfield, Donnelly) alleging plan creation and supervision of the operation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Supervisory liability plausibility | Santiago asserts Murphy and Donnelly directed the violation; Springfield acquiesced. | Plaintiff's claims are conclusory and fail under Twombly/Iqbal to show plausibility. | Dismissal affirmed; claims not plausibly alleged. |
| Causation via Monell policy | Chief Murphy acted as final policymaker; plan caused injuries. | Plaintiff failed to plead a policy or final policymaker; plan not shown to cause injury. | Warminster claim insufficient; no plausible Monell policy showing injury. |
| Plausibility of plan to use force against all occupants | Plan targeted all occupants with force; officer conduct reflects plan. | Allegations do not show a uniform plan; force against Santiago could be discretionary. | Plan to use force not plausibly alleged; insufficient to sustain supervisory liability. |
| Knowledge/acquiescence by Lt. Springfield | Springfield knew of/excused excessive force during raid. | Complaint cannot show Springfield knew or acquiesced; presence not enough. | Insufficient pleading to show knowledge/acquiescence; not plausible. |
| Twombly/Iqbal pleading standard application | Non-conclusory facts support plausible claims against supervisors. | Conclusions restating elements are insufficient after Iqbal. | Court applied Twombly/Iqbal; claims fail to reach plausibility threshold. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (U.S. 2009) (conclusion warrants for dismissal if not plausible)
- Monell v. Dep't of Soc. Servs. of N.Y., 436 U.S. 658 (U.S. 1978) (local government liability requires policy or custom)
- City of Los Angeles v. Heller, 475 U.S. 796 (U.S. 1986) (supervisor liability requires direct violation or acquiescence with causation)
- A.M. ex rel. J.M.K. v. Luzerne Cnty. Juvenile Det. Ctr., 372 F.3d 572 (3d Cir. 2004) (supervisory liability requires directing or acquiescing in violations)
- Conner v. Reinhard, 847 F.2d 384 (7th Cir. 1988) (proximate causation in supervisory liability)
- McTernan v. City of York, 564 F.3d 636 (3d Cir. 2009) (plausibility standard context in supervisory liability)
- McGreal v. Ostrov, 368 F.3d 657 (7th Cir. 2004) (policy vs. individual liability concepts)
- City of St. Louis v. Praprotnik, 485 U.S. 112 (U.S. 1988) (policymaker identification in municipal liability)