United States District Court, N.D. Alabama, Southern Division
BRIAN J. BENDER, et al., Plaintiffs,
GREG CORAM, et al., Defendants.
KARON OWEN BOWDRE, Chief District Judge.
On October 17, 2008, Defendant Barbara Zezulka allegedly entered false information into the Alabama Criminal Justice Information System ("ACJIS") and the National Crime Information Center database ("NCIC"), indicating that Plaintiff Tonya Bell had an outstanding warrant for her arrest. On October 25, 2008, Defendants Greg Coram and Brad Richardson, officers with the Hueytown Police Department, saw three black youths-Plaintiffs Bobby Joe Bell, Christopher Burts, and Brian J. Bender, Jr.- driving a vehicle registered to Ms. Bell. Based on the false arrest warrant, the officers stopped and searched the car, detaining the boys for roughly an hour. The boys along with their parents, Plaintiffs Tonya Bell, Uvonne Bell, and Valerie Thomas, subsequently brought suit against the Defendants on August, 14, 2014.
In their complaint, Mr. Bender, Mr. Bell, and Mr. Burts assert claims against all three Defendants for unlawful arrest under § 1983 and false imprisonment under Alabama state law. Mr. Bender, Mr. Bell, and Mr. Burts also assert additional § 1983 claims against only Defendants Coram and Richardson. Finally, Ms. Tonya Bell, Ms. Uvonne Bell, and Ms. Valerie Thomas assert state law claims for loss of service against all three Defendants.
Since filling their complaint, the Plaintiffs have moved to voluntarily dismiss many of their claims. First, Ms. Tonya Bell, Ms. Uvonne Bell, and Ms. Valerie Thomas filed a voluntary motion to dismiss their loss of service claim with prejudice (doc. 22), which the court will grant. Additionally, Mr. Bender, Mr. Bell, and Mr. Burts entered a notice of dismissal with prejudice as to all claims against Officers Coram and Richardson. (Doc. 23). As such, the only remaining claims are those against Ms. Zezulka brought by Mr. Bender, Mr. Bell, and Mr. Burts-the § 1983 unlawful arrest claims and the state-law false imprisonment claims.
This matter is now before the court on Ms. Zezulka s motion to dismiss. (Doc. 11). For the reasons discussed below, the court will GRANT IN PART Ms. Zezulka's motion to dismiss Mr. Bender, Mr. Bell, and Mr. Burts' state-law false imprisonment claims and Mr. Bell and Burts' § 1983 unlawful arrest claims. The court will DENY Ms. Zezulka s motion to dismiss only as to Mr. Bender's § 1983 claim.
I. STANDARD OF REVIEW
A Rule 12(b)(6) motion to dismiss attacks the legal sufficiency of the complaint. Generally, the Federal Rules of Civil Procedure require only that the complaint provide "a short and plain statement of the claim' that will give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Conley v. Gibson, 355 U.S. 41, 47 (1957) (quoting Fed.R.Civ.P. 8(a)). A plaintiff must provide the grounds of his entitlement, but Rule 8 generally does not require "detailed factual allegations." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley, 355 U.S. at 47).
The Supreme Court explained that "[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting and explaining its decision in Twombly, 550 U.S. at 570). To be plausible on its face, the claim must contain enough facts that "allow the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Iqbal, 556 U.S. at 678. Although "[t]he plausibility standard is not akin to a probability requirement, '" the complaint must demonstrate "more than a sheer possibility that a defendant has acted unlawfully." Id. If the court determines that well-pleaded facts, accepted as true, do not state a claim that is plausible, the claim must be dismissed. Id.
II. STATEMENT OF FACTS
On October 25, 2008, Plaintiff Bobby Joe Bell drove his aunt's Ford Focus through Hueytown, Alabama. In the car with Mr. Bell were Plaintiffs Christopher Burts and Brian Bender, Jr. The three boys, all black males, bobbed their heads to the rhythm of the music emanating from the car stereo as they meandered toward the home of Tonya Bell, Mr. Bell's aunt and the owner of the Ford Focus. Defendants Coram and Richardson were on patrol that day and observed the boys driving the vehicle. After following the boys for three or four blocks, the officers ran the tags on the Ford Focus, which came back as belonging to Tonya Bell.
The officers then ran Ms. Bell's information through the ACJIS and NCIC warrant databases, which indicated that Ms. Bell had an outstanding arrest warrant. The information on the databases, however, was incorrect; Ms. Bell did not actually have a warrant for her arrest. Rather, Defendant Zezulka allegedly had intentionally entered information into the database falsely indicating that Ms. Bell had a warrant for her arrest.
Officers Coram and Richardson, unaware that the information was false, pulled the vehicle over. The two officers approached the vehicle and asked Mr. Bell for his license and insurance. The officers then returned to their police cruiser and ran Mr. Bell's information. After finding no outstanding warrants for Mr. Bell, Officer Coram again approached the vehicle and accused the boys of turning without using a blinker and smoking marijuana. The boys denied both accusations, but the officers instructed the boys to exit the vehicle. The officers then pat searched the boys and rummaged through the vehicle without the boys' consent.
Forty-five minutes after the officers initiated the stop, another Hueytown police officer arrived on the scene and instructed Officers Coram and Richardson to release the boys. Officer Coram wrote Mr. Bell a warning ticket for failing to signal and then ...