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Edwards v. Rougeau

United States District Court, E.D. Michigan, Southern Division

February 24, 2017

ANTHONY EDWARDS, Plaintiff,
v.
BRADLEY ROUGEAU et al., Defendants.

          OPINION AND ORDER GRANTING DEFENDANT BRADLEY ROUGEAU'S MOTION FOR JUDGMENT ON THE PLEADINGS (ECF #33)

          MATTHEW F. LEITMAN, UNITED STATES DISTRICT JUDGE

         This civil action arises from an unfortunate case of mistaken identity. In 2013, a state court issued a warrant for the arrest of Plaintiff Anthony Edwards (“Edwards”) on multiple felony drug charges (see ECF #40-1 at Pg. ID 259), and law enforcement officers arrested Edwards pursuant to that warrant. It turns out that Edwards had not broken the law and that the warrant was issued erroneously. The real criminal had apparently stolen Edwards' identity and committed the crimes using that identity, and that led to the mix-up in the warrant. Edwards spent approximately eight days in custody before his identity was confirmed and he was released. In this action, Edwards seeks to hold several law enforcement officers liable for his erroneous arrest and detention.

         Defendant Bradley Rougeau (“Rougeau”) has moved for judgment on the pleadings on the claims against him under Rule 12(c) of the Federal Rules of Civil Procedure (the “Motion”). (See ECF #33.) For the reasons explained below, the Court GRANTS the Motion and DISMISSES WITH PREJUDICE Edwards' claims against Rougeau.

         I

         Edwards' First Amended Complaint is short on details concerning his claims against Rougeau. He alleges that Rougeau is employed by the Ann Arbor Police Department and assigned (along with the seven other named Defendants) to a taskforce known as LAWNET (see First Am. Compl. at ¶2, ECF # 12 at Pg. ID 55); that on October 2, 2103, unidentified officers of LAWNET arrested him (Edwards) on “an outstanding warrant for his arrest on a charge of dangerous drugs” (Id. at ¶10, ECF #12 at Pg. ID 56); and that he (Edwards) immediately told the arresting officers “that they had arrested the wrong person” and that someone had previously stolen his identity (id. at ¶¶ 11-12, ECF #12 at Pg. ID 56-57).

         Edwards claims that he was arraigned on October 3, 2013, and that at the arraignment, the presiding judge “ordered that Sheriff Clayton [who is not a party to this action] take Edwards' fingerprints in order to determine whether Edwards was the correct individual to be arrested.” (Id. at ¶¶ 13-15, ECF #12 at Pg. ID 57.) Edwards says that the “Defendants [then] waited more than five days to determine whether [he] was the correct individual to be arrested” and that during that time he remained in custody. (Id. at ¶16, ECF #12 at Pg. ID 57.) On October 10, 2013, the charges against Edwards were dismissed. (See Id. at ¶¶ 18-19, ECF #12 at Pg. ID 57.)

         Edwards insists that the “Defendants determined or should have determined that [he] was not the individual who was [the] subject of the arrest warrant on October 2, 2013.” (Id. at ¶17, ECF #12 at Pg. ID 57.) Edwards complains that “Defendants' acts of failing to timely release [him] from jail deprived [him] of his constitutional right to be free from wrongful or false imprisonment, as guaranteed by the Fourth and Fourteenth Amendments to the United States Constitution.” (Id. at ¶22, ECF #12 at Pg. ID 58.)

         The Amended Complaint contains only a single substantive allegation that mentions Rougeau by name:

Defendant Detective Bradley Rougeau had visual or other identification of Edwards after he was arrested, and was able to visually or otherwise confirm that Edwards was not the subject who was the subject of the arrest warrant. Despite having knowledge that Edwards was not the individual who was the subject of the arrest warrant, Defendant Rougeau continued to have Edwards detained at the Washtenaw County Jail.

(Id. at ¶31, ECF #12 at Pg. ID 60.) Edwards makes the exact same allegation - verbatim - against each of the other seven Defendants. (See, e.g., id. at ¶¶ 32-38, ECF #12 at Pg. ID 60-62.)

         II

         Before turning the merits of Rougeau's motion, the Court pauses to clarify the governing legal standard. Rougeau seeks dismissal under Rule 12(c) of the Federal Rules of Civil Procedure. Both parties agree that the standard for dismissal under Rule 12(c) is the same as the standard under Rule 12(b)(6). (See Rougeau Mot. at 3, ECF #33 at Pg. ID 199; Edwards Resp. Br. at 9, ECF #37 at Pg. ID 236.)

         Edwards argues that in order to prevail under that standard, Rougeau “must demonstrate [that] the plaintiff can prove no set of facts in support of the claims that would entitled him to relief.” (Edwards Resp. Br. at 6, ECF #37 at Pg. ID 233) (quoting Southwest Williamson County Cmty. Ass'n v. Slater, 173 F.3d 1022, 1035 (6th Cir. 1999).) However, the Supreme Court jettisoned the “can prove no set of facts” standard in Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 561-63 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009). Thus, Edwards' reliance on that standard is misplaced.

         “To survive a motion to dismiss” under the Rule 12(b)(6) standard that applies here, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.'” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). A claim is facially plausible when a plaintiff pleads factual content that permits a court to reasonably infer that the defendant is liable for the alleged misconduct. Id. (citing Twombly, 550 U.S. at 556). When assessing the sufficiency of a plaintiff's claim, a district court must accept all of a complaint's factual allegations as true. See Ziegler v. IBP Hog Mkt., Inc., 249 F.3d 509, 512 (6th Cir. 2001). “Mere conclusions, ” however, “are not entitled to the assumption of truth. While legal conclusions can provide the complaint's framework, they must be supported by factual allegations.” Iqbal, 556 U.S. at 664. A plaintiff must therefore provide “more than labels and conclusions, ” or “a ...


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