Thornton v. State, 2015 Ind. LEXIS 1067

Randy Thornton sued multiple defendants after being jailed for an alleged probation violation that he claims occurred after his probation term had expired.
He sued four individual Marion County probation officers under 42 U.S.C. § 1983, among other claims against state and municipal defendants.
The trial court dismissed all claims; the Court of Appeals affirmed in a memorandum decision.
On transfer, Thornton challenged only the dismissal of his § 1983 claim against the four individual probation officers.
Defendants moved to dismiss under Ind. Trial Rule 12(B)(6), principally arguing the claim was time-barred and that they were entitled to quasi-judicial immunity.
The trial court dismissed for failure to state a claim; the Court of Appeals sua sponte affirmed on that basis. The Indiana Supreme Court granted transfer and reversed dismissal of Thornton’s § 1983 claim, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thornton pleaded a § 1983 claim against individual probation officers	Thornton alleged probation officers, acting under color of state law, deprived him of liberty and due process — sufficient under § 1983	The complaint failed to state a claim and was time-barred; alternatively, officers have quasi‑judicial immunity	The complaint adequately pleaded a § 1983 claim; dismissal for failure to state a claim was error; remand for further proceedings
Whether dismissal could be affirmed on statute of limitations grounds	Thornton did not prevail on that ground on transfer	Defendants argued the claim was filed after the limitations period	Defendants did not press the statute‑of‑limitations argument on transfer and the Court found it unpersuasive
Whether quasi‑judicial immunity bars the § 1983 claim	Thornton argued immunity was not established on the face of the complaint	Defendants asserted quasi‑judicial immunity applicable to probation officers	Court held the record was insufficient to resolve immunity; remand required to explore the nature of the function performed
Standard for Rule 12(B)(6) dismissal	Thornton argued his allegations, viewed in the light most favorable to him, state a claim	Defendants urged dismissal as legally insufficient	Court reiterated de novo review and that pleadings must be accepted in the nonmovant’s favor; dismissal improper when facts could support relief

Kitchell v. Franklin, 997 N.E.2d 1020 (Ind. 2013) (standards for evaluating a T.R. 12(B)(6) motion)
City of E. Chicago v. E. Chicago Second Century, Inc., 908 N.E.2d 611 (Ind. 2009) (pleadings must be capable of supporting relief to sustain dismissal)
Bayh v. Sonnenburg, 573 N.E.2d 398 (Ind. 1991) (§ 1983 provides remedy for deprivation of federal rights under color of state law)
Gomez v. Toledo, 446 U.S. 635 (U.S. 1980) (elements required to plead a § 1983 claim)
In re Tina T., 579 N.E.2d 48 (Ind. 1991) (§ 1983 pleading sufficiency)
Mendenhall v. City of Indianapolis, 717 N.E.2d 1218 (Ind. Ct. App. 1999) (quasi‑judicial immunity focuses on function performed)
Forrester v. White, 484 U.S. 219 (U.S. 1988) (immunity analysis based on function, not identity)
City of New Haven v. Reichhart, 748 N.E.2d 374 (Ind. 2001) (affirmance of dismissal may rest on any sustainable ground in the record)
Minks v. Pina, 709 N.E.2d 379 (Ind. Ct. App. 1999) (same)