Saunders v. Raleigh County
5:20-cv-00221
| S.D.W. Va | May 18, 2020Background
- On February 1, 2018 Rayco Saunders was stopped in Raleigh County, WV; officer Bowers concluded Saunders displayed fraudulent Pennsylvania "Traveler" plates and a counterfeit ID, arrested him, and his vehicle was towed. Saunders was detained at Southern Regional Jail (SRJ) for about 12 days and posted bond on February 14, 2018.
- Saunders removed state criminal proceedings to Raleigh County Circuit Court, pursued writs to the West Virginia Supreme Court (which refused/dismissed them), and the state charges were ultimately dismissed in July 2019 as part of a mass dismissal.
- Saunders (pro se) sued in federal court (filed Jan. 7, 2020) asserting claims under 42 U.S.C. §§ 1983, 1985, 1986 and various state tort and constitutional theories against many defendants: SRJ, City of Beckley, Raleigh County, officers Bowers and White, prosecutors Keller and Parsons, Judge Dimlich, Magistrates Peck and Humphrey, and Asst. AG Johnson.
- Defendants moved to dismiss on multiple grounds: Eleventh Amendment immunity for SRJ/state entities, absolute judicial/prosecutorial immunity, qualified immunity for officers, failure to plead a Monell claim against municipal defendants, statute-of-limitations bars, and failure to state plausible claims under Twombly/Iqbal.
- The magistrate judge screened the pro se complaint under 28 U.S.C. § 1915A and recommended dismissal with prejudice, concluding (inter alia) that many claims were time-barred, legally frivolous, non-cognizable, or barred by immunity; subsequent motions responding to the amended complaint were deemed moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1) Municipal / jail liability (Monell) | Saunders says City of Beckley and Raleigh County are liable for customs/policies that caused his harms (SRJ conditions, failure to train). | City/County: SRJ is a state entity; City/County did not operate SRJ; no municipal policy or facts pleaded to satisfy Monell. | Dismissed: plaintiff failed to plead Monell policy/custom facts; City/County have no control over SRJ. |
| 2) Eleventh Amendment & SRJ as defendant | Saunders sues SRJ directly. | SRJ (state authority) is not a "person" under § 1983 and is entitled to sovereign immunity. | Dismissed: SRJ immune from § 1983 damages under Eleventh Amendment. |
| 3) Judicial/prosecutorial immunity | Saunders alleges judges/prosecutors caused wrongful process. | Judges (Dimlich, Peck, Humphrey) and prosecutors (Keller, Parsons, Johnson) are absolutely immune for judicial/prosecutorial acts. | Dismissed: absolute judicial and prosecutorial immunity applies to the challenged acts. |
| 4) Fourth Amendment (false arrest / malicious prosecution) & qualified immunity | Saunders contends arrest and subsequent complaints were false and malicious. | Defendants assert probable cause existed (fake plates/ID); qualified immunity protects officers and prosecutors; malicious-prosecution elements not met. | Dismissed: probable cause supported arrest; qualified immunity applies; malicious prosecution/false arrest claims fail. |
| 5) Conditions of confinement (Eighth/Fourteenth Amendments) | Saunders alleges 12-day detention with lights on, no bed, no hygiene, denial of bail and recreation caused constitutional injury. | Defendants: short-term deprivations do not meet objective/subjective Eighth/Fourteenth Amendment standards; no specific serious injury alleged. | Dismissed: conditions, as pleaded, do not constitute cruel and unusual punishment or deliberate indifference. |
| 6) Conspiracy (§ 1985/§ 1986), abuse of process, and other torts | Saunders alleges a conspiracy to deprive rights, abuse of process, IIED, fraud, etc. | Defendants: allegations are conclusory, lack concrete supporting facts; abuse of process and many state torts are time-barred. | Dismissed: conspiracy and § 1986 claims inadequately pleaded; abuse of process and many tort claims barred by statute of limitations or fail on merits. |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires policy or custom)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (states and state agencies are not "persons" under § 1983 for money damages)
- Imbler v. Pachtman, 424 U.S. 409 (prosecutorial absolute immunity for initiating/presenting prosecution)
- Malley v. Briggs, 475 U.S. 335 (qualified immunity and objective reasonableness of probable cause for arrests/complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (heightened pleading; no naked assertions)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for inmates)
- Graham v. Connor, 490 U.S. 386 (objective reasonableness for excessive-force/Seizure analysis)
- Wallace v. Kato, 549 U.S. 384 (accrual rules for false arrest/imprisonment and malicious prosecution)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step analysis)
- Wilson v. Seiter, 501 U.S. 294 (conditions-of-confinement test)
- Lambert v. Williams, 223 F.3d 257 (4th Cir. on § 1983 malicious-prosecution analysis)
- Brooks v. City of Winston–Salem, 85 F.3d 178 (4th Cir. elements for § 1983 seizure-based claims)
- Burrell v. Virginia, 395 F.3d 508 (4th Cir. requirement that prosecution must terminate in plaintiff's favor for malicious prosecution under § 1983)