Young v. Stenger

Background

Lamar Young filed a civil-rights action under 42 U.S.C. § 1983 while in custody and representing himself. He originally sued Sgt. Stenger and Detectives Inabnett, Mellone, and Bledsoe, seeking monetary and punitive damages. Young alleged that, during an interrogation on October 29, 2020, the defendants used excessive force when they forced him to wear a mask after he refused to wear one at the officers’ request.

The court had previously screened the original complaint and found a legally cognizable Fourth Amendment excessive-force claim against Stenger, Mellone, and Bledsoe, along with a claim against Inabnett for allegedly failing to intervene. The defendants were served and filed an answer.

Amended complaint

Young moved for leave to amend and filed an amended complaint. The amended complaint named the same defendants, made some minor changes to the factual allegations, and attempted to assert excessive-force claims under the Eighth and Fourteenth Amendments. It also asserted a state-law negligence claim against Stenger for allegedly failing to prevent a “safety issue.”

The court granted Young’s motions for leave to file an amended complaint. The amended complaint became the operative complaint. Applying the required screening process for a complaint filed by a person in custody, the court found that it stated:

- A cognizable Fourth Amendment excessive-force claim against Stenger, Mellone, and Bledsoe; - A cognizable Fourth Amendment claim against Inabnett for allegedly failing to intervene; and - A supplemental state-law negligence claim against Stenger.

The court explained that the Fourth Amendment’s reasonableness standard applies to alleged excessive force against a person detained after arrest but before arraignment. Because Young was not a convicted prisoner when the incident occurred, the court did not treat the allegations as an Eighth Amendment claim. All other claims were dismissed without prejudice.

Other motions and case schedule

The court denied Young’s request for default judgment. No default had been entered against the defendants, and they had filed an answer, so the court concluded that default judgment was unavailable.

The court denied as moot the defendants’ motion for an extension of time to file a summary-judgment motion because it issued a new briefing schedule. The defendants were ordered to file a summary-judgment or other dispositive motion within 45 days of the order. Young’s opposition was due 28 days after the motion, and the defendants’ reply was due 14 days after the opposition. The order also allowed discovery under the Federal Rules of Civil Procedure and granted defendants permission to depose Young and other necessary witnesses confined in prison.

Disposition

Judge Donna M. Ryu granted Young’s motions for leave to file an amended complaint; found the specified Fourth Amendment and negligence claims cognizable; dismissed all other claims without prejudice; denied Young’s request for default judgment; and denied as moot the defendants’ motion for an extension of time. The case was allowed to proceed under the new briefing schedule.