Truvillion v. Seattle Police Department
2:25-cv-00874
W.D. Wash.Jun 3, 2025Background
- Plaintiff Roosevelt Truvillion filed a complaint under 42 U.S.C. § 1983 against the Seattle Police Department, alleging failure to investigate a purported hate crime and death threats.
- Plaintiff was granted in forma pauperis status, which triggers the Court’s obligation to review and dismiss complaints that fail to state a claim under 28 U.S.C. § 1915(e)(2)(B).
- The complaint alleged that Defendant "failed to serve and protect" and "discriminated" but included only general assertions with no supporting factual details.
- The Court found that the complaint contained only conclusory allegations and did not provide plausible facts to infer liability.
- The case was dismissed without prejudice, granting Plaintiff leave to amend with specific factual allegations by July 3, 2025.
- The Court cautioned Plaintiff to provide accurate information about prior federal lawsuits in any future filings, referencing at least four previous cases filed by Plaintiff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the factual allegations in the complaint | SPD failed to protect/investigate; suffered discrimination | Not specified (motion on the Court's own initiative) | Plaintiff’s complaint lacked sufficient factual detail; dismissed with leave to amend. |
| Plausible claim under 42 U.S.C. § 1983 | Rights violated by SPD's inaction | Not specified | Conclusory statements insufficient for § 1983 claim. |
| Obligation to amend pro se complaints | Not specifically argued | Not specifically argued | Plaintiff can amend; leave to file amended complaint granted. |
| Accuracy of prior lawsuit disclosures | Claimed no prior cases filed | N/A | Plaintiff misrepresented prior federal filings; warned to comply with Rule 11. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requires sufficient facts to state a plausible claim for relief)
- Ashcroft v. Iqbal, 556 U.S. 662 (complaints must include factual content allowing the court to infer liability)
- Lopez v. Smith, 203 F.3d 1122 (section 1915(e) applies to all IFP complaints, not just those by prisoners)
- Johnson v. Lucent Techs. Inc., 653 F.3d 1000 (courts construe pro se complaints liberally)