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Robinson v. Genesee County Sheriff's Department

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

March 24, 2017

AARON ANTWAUN ROBINSON, Plaintiff,
v.
GENESEE COUNTY SHERIFF'S DEPARTMENT, et al, Defendants.

         ORDER GRANTING MOTION FOR MORE DEFINITE STATEMENT, MOTION TO DISMISS THE GENESEE COUNTY SHERIFF'S DEPARTMENT, MOTION TO EXTEND SUMMONS, AND MOTION TO QUASH, AND DENYING MOTION TO SUBSTITUTE PARTY, MOTION TO VACATE, AND MOTION TO FILE AMENDED COMPLAINT AND DISMISSING GENESEE COUNTY SHERIFF'S DEPARTMENT

          Honorable Thomas L. Ludington, Judge

         On October 26, 2016, Plaintiff Aaron Robinson filed a complaint which alleged that Defendants Genesee County Sheriff's Department, Sergeant Gerald Park, Deputy Ryan Rainwater, Deputy F/N/U Hoover, and ten other John Does repeatedly beat and otherwise mistreated Robinson while he was confined in the Genesee County Jail. ECF No. 1. Defendant Rainwater was served on December 16, 2016. In response to the complaint, Rainwater filed a motion for a more definite statement, ECF No. 6, seeking additional information regarding “which Defendant allegedly committed what tort and when.” Id. at 4. Several days later, the Court directed Robinson to disclose his place of residence so the Court could confirm that the case had been properly assigned to the Northern Division of the Eastern District of Michigan.[1]

         On January 16, 2017, the Genesee County Sheriff's Department appeared for the purpose of filing a motion to dismiss, arguing that a sheriff's department is not an independent legal entity that is amenable to suit under Michigan law. ECF No. 14. On January 30, 2017, Robinson filed a motion to substitute Genesee County for the Sheriff's Department as a Defendant, acknowledging that the Sheriff's Department should not have been named as a Defendant.

         Around the same time, Robinson filed a motion to extend the deadline to serve the remaining Defendants. ECF No. 15. Six days after that motion was filed, the Court granted a thirty day extension of the deadline, to February 24, 2017. ECF No. 16. On February 13, 2017, Rainwater filed a motion to vacate the Court's order extending the service deadline. ECF No. 23. The next day, Robinson filed a second motion to extend the service deadline. ECF No. 25. Robinson also filed a motion to amend his complaint. ECF No. 26. Finally, on February 22, 2017, the Genesee County Sheriff's Department filed a motion to quash a subpoena which Robinson sent to the Department.

         For the reasons stated below, the motion for a more definite statement, motion to dismiss, motion to extend, and motion to quash will be granted, and the motion to substitute, motion to vacate, and motion to file an amended complaint will be denied.

         I.

         According to the allegations in Robinson's complaint, he was arrested in 2011 and charged with killing a Genesee County Sheriff Lieutenant. Compl. at 3, ECF No. 1. Robinson was acquitted of that charge, but is currently incarcerated after being convicted of unrelated offenses. Id. Robinson was held in the Genesee County Jail for two years while awaiting his trial on the murder charge. Id. at 4. According to Robinson, “[d]uring that time he was repeatedly beaten and assaulted by the Defendants herein.” Id. Robinson is confident that the named Defendants beat him, but also alleges that he was beaten by “numerous other deputies or personnel of the Genesee County Sheriff's Department whose names are unknown to him, but who he could identify through photographs of the staff of the Genesee County Sheriff's Department and jail from 2011 to 2013.” Id.

         Robinson further alleges that, when he attempted to file grievances or lawsuits concerning his mistreatment, “he was continuously and without cause placed in segregation” and his “legal papers and other documents were confiscated and/or destroyed.” Id. Robinson also alleges that some of the acts were captured by video cameras inside the jail. Id.

         In Count One of his complaint, Robinson alleges that his First Amendment, due process, and Eighth Amendment rights were violated. In the second Count, Robinson alleges that the Genesee County Sheriff's Department tolerated, condoned, and encouraged the abuse he suffered to the extent that it was the “actual, but unwritten, policy and practice” of the Department. Id. at 7. In Count Three, Robinson alleges that Defendants were engaged in a conspiracy to violate his civil and constitutional rights during his incarceration at the Genesee County Jail. Id. Finally, Robinson brings several state claims: assault and battery and intentional infliction of emotional and mental distress. Id. at 8.

         II.

         The Genesee County Sheriff's Department has moved to be dismissed for failure to state a claim against it. A pleading fails to state a claim under Rule 12(b)(6) if it does not contain allegations that support recovery under any recognizable legal theory. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). In considering a Rule 12(b)(6) motion, courts construe the pleading in the non-movant's favor and accepts the allegations of facts therein as true. See Lambert, 517 F.3d at 439. The pleader need not provide “detailed factual allegations” to survive dismissal, but the “obligation to provide the ‘grounds' of his ‘entitle[ment] to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). In essence, the pleading “must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face” and “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.” Iqbal, 556 U.S. at 678-79 (quotations and citation omitted).

         Defendant Rainwater has also moved for a more definite statement. Federal Rule of Civil Procedure 12(e) stated that:

A party may move for a more definite statement of a pleading to which a responsive pleading is allowed but which is so vague or ambiguous that the party cannot reasonably prepare a response. The motion must be made before filing a responsive pleading and must point out the defects complained of and the details desired. If the court orders a more definite statement and the order is not obeyed within 14 days after notice of the order or within the time the court sets, the court may strike the pleading or issue any other appropriate order.

Id.

         Generally speaking, “motions for more definite statements are disfavored.” Farah v. Martin, 122 F.R.D. 24, 25 (E.D. Mich. 1988). Pleadings are typically “sufficient if they provide defendants with notice.” Id. In that case, ambiguities or vagueness in the complaint should be cured through discovery, not motions practice. Fed. Ins. Co. v. Webne, 513 F.Supp.2d 921, 924 (N.D. Ohio 2007). However, civil rights cases where government entities and employees are being sued “require greater particularity.” Farah, 122 F.R.D. at 26. That is because defending the case will require the defendants to “divert their attention from their usual activities and to become involved in the litigation to the neglect of their assigned duties.” Chapman v. City of Detroit, 808 F.2d 459, 465 (6th Cir. 1986).

         III.

         First, the motions regarding Robinson's claims against the Genesee County Sheriff's Department will be addressed. Second, Robinson's motion to file an amended complaint will be considered. But because the proposed amended complaint does not provide a sufficiently definite statement of Robinson's claims, the motion for a more definite statement will be granted and the motion to file an amended complaint will be denied as futile. Finally, the motions regarding extension of the service deadlines and the motion to quash will be resolved.

         A.

         The Genesee County Sheriff's Department has moved to be dismissed. ECF No. 14. The Department correctly points out that, under the Michigan Constitution, sheriff departments are agencies of the county, not a separate legal entity which can be sued. See Mich. Const. art. 7, § 4. See also Vine v. Cty. of Ingham, 884 F.Supp. 1153, 1158 (W.D. Mich. 1995). Robinson agrees that the Genesee County Sheriff's Department should not have been named as ...


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