STADLER v. ABRAMS
1:13-cv-02741-RBK-AMD
D.N.J.Oct 4, 2017Background
- On March 13, 2013 Steven M. Stadler was confronted at an Atlantic City car wash while allegedly opening a coin box; Officer Glenn Abrams (off-duty) called 911 and other ACPD officers (Moore, Devlin) arrived with K-9 Clancy.
- Stadler contends he fled, was punched and knee-struck by officers, and bitten by the K-9; he sustained facial injuries, a severely injured left thigh, and lasting scarring/nerve complaints.
- Officers report Stadler resisted arrest; Stadler later pleaded guilty to burglary and resisting arrest but disputes the officers’ use of force.
- Plaintiff sued under 42 U.S.C. § 1983 for excessive force against the individual officers and brought a Monell claim against Atlantic City for customs, practices, and failures to train/supervise concerning use of force and K-9 deployments.
- Evidence submitted by Plaintiff: numerous ACPD internal complaints (including many for excessive force), an OLEPS review noting concentrated use-of-force incidents among certain officers, and expert testimony alleging ACPD’s internal affairs tracking and early-warning system were ineffective.
- The court denied summary judgment to the individual officers and to Atlantic City, finding genuine disputes of material fact on excessive force and municipal liability and that the city failed to carry its Rule 56 burden to negate Plaintiff’s customs/traininga claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers used objectively unreasonable force in seizing Stadler (Fourth Amendment excessive force) | Stadler: officers beat him, deployed K-9 gratuitously, causing severe injuries — testimony and medical/photographic evidence create a triable dispute | Officers: dispute facts; argue some officers not alleged in pro se complaint or not involved; resisting-arrest plea undermines claim | Denied summary judgment for officers — genuine factual disputes exist; plea to resisting arrest does not necessarily bar § 1983 claim |
| Whether Officer Moore can be held liable despite not named in original pro se complaint | Moore was present and admits knee strikes; Plaintiff later amended complaint to add Moore; testimony supports involvement | Defendants argue pro se omission and medical records undermine Moore’s involvement | Denied — amended complaint controls; Moore’s own admissions and Plaintiff testimony create triable issues |
| Whether Stadler’s guilty plea to resisting arrest precludes excessive force claim (Heck doctrine) | Stadler: plea does not necessarily invalidate a § 1983 excessive-force claim | Defendants: plea forecloses challenge to lawfulness of arrest and use of force | Denied — Heck requires that a § 1983 victory would invalidate the conviction; resisting-arrest conviction does not necessarily bar excessive-force damages claim |
| Whether Atlantic City is liable under Monell for customs/failure to train/supervise re: excessive force and K-9 use | Stadler: widespread complaints, ineffective IA/EWS, OLEPS findings, and training/supervision failures causally link municipal policy/custom to harm | Atlantic City: argues no constitutional violation or else conduct so egregious municipal policy irrelevant; also failed to present adequate Rule 56.1 facts on policies | Denied — city failed to meet Rule 56 burden; Plaintiff produced evidence of customs/training failures and triable causal issues |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (Fourth Amendment objective-reasonableness test for use of force)
- Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s burden on summary judgment and methods to satisfy it)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for genuine dispute of material fact on summary judgment)
- Heck v. Humphrey, 512 U.S. 477 (when § 1983 damages claim is barred by prior conviction)
- Monell v. Department of Social Services of City of New York, 436 U.S. 658 (municipal liability under § 1983 requires policy/custom causation)
- City of Canton v. Harris, 489 U.S. 378 (failure-to-train municipal liability standards)
- Kopec v. Tate, 361 F.3d 772 (Third Circuit on summary judgment and reasonableness review of force)
- Rivas v. City of Passaic, 365 F.3d 181 (Fourth Amendment reasonableness from officer perspective)
- Smith v. Mensinger, 293 F.3d 641 (inability of plaintiff to identify assailants does not negate liability)