Townsend v. Coffee County
2011 U.S. Dist. LEXIS 154906
S.D. Ga.2011Background
- Townsend, a black female, was involved in a police stop incident in Coffee County, GA on Dec 2, 2008; Deputy Grantham drew a gun, handcuffed Townsend, and treated her differently than a white motorist who was present; Townsend injured her right arm and required medical treatment; Townsend sued Grantham (individually and officially) and Coffee County for various federal and state-law claims; Defendants removed to federal court and moved to dismiss under Rule 12(b)(6); Court considers the complaint as true for purposes of the motion and discusses Monell/Eleventh Amendment immunity, qualified immunity, and procedural/fourteenth amendment claims; Court ultimately grants dismissal of all claims and declines supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Coffee County can be liable under §1983 | Grech controls; county policy or custom caused injury | County has no control over sheriff's training/hiring; no policy | Coffee County claims dismissed under Monell/Grech; no policy/control shown |
| Eleventh Amendment immunity for Grantham in official capacity | Deputy should be liable in federal court | Sheriff/deputy are arms of the state; immunity applies | Grantham entitled to Eleventh Amendment immunity in official capacity; §1983 claims dismissed |
| Qualified immunity for Grantham on Fourth Amendment excessive force claims | Use of force was excessive/inappropriate | Force was reasonable; not clearly established violation | Grantham entitled to qualified immunity; excessive force claim dismissed |
| Qualified immunity for Grantham on Fourth Amendment unreasonable seizure | Arrest without probable cause | Arguable probable cause for obstruction; totality of circumstances | Grantham entitled to qualified immunity; unreasonable seizure claim dismissed |
| Procedural/substantive due process, equal protection, and state-law claims | Due process/EP claims persist | Claims fail under 4th Amendment analysis or lack of state-law basis | Procedural and substantive due process claims dismissed; equal protection claim addressed and rejected; state-law claims declined under 28 U.S.C. §1367(c)(3) |
Key Cases Cited
- Grech v. Clayton Cnty., 335 F.3d 1326 (11th Cir. 2003) (county sheriffs not county actors; sheriffs independent from county; Monell backdrop)
- Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003) (factors for determining state arm status of sheriff/deputy)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1983) (municipal liability requires policy/custom; not respondeat superior)
- Jones v. City of Dothan, 121 F.3d 1456 (11th Cir. 1997) (excessive force analysis; varying degree of force; qualified immunity)
- Graham v. Connor, 490 U.S. 386 (1989) (reasonableness standard for stop/seizure actions under Fourth Amendment)
- Kesinger ex rel. Estate of Kesinger v. Herrington, 381 F.3d 1243 (11th Cir. 2004) (Fourth Amendment reasonableness governs excessive-force claims at arrest/stop)
- Shop v. City of Atlanta, 485 F.3d 1130 (11th Cir. 2007) (probable-cause standard in arrests; arguable probable cause standard)
- Gutierrez v. City of San Antonio, 139 F.3d 441 (5th Cir. 1998) (Fourteenth Amendment timing after arrest; pretrial detention context)