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HomeMy WebLinkAbout2021-cv-2306-RM-KLM - Perry V. State Of Colorado, Et Al - 030 - Exhibit Neutral As of: October 8, 2021 1:51 AM Z Alexander v. Lucas United States Court of Appeals for the Tenth Circuit December 21, 2007, Filed No. 07-6106 Reporter 259 Fed. Appx. 145 *; 2007 U.S. App. LEXIS 29745 ** ALVIN LYNN ALEXANDER, Plaintiff-Appellant, v. HONORABLE TOM A. LUCAS; HONORABLE GARY L. LUMPKIN; CLEVELAND COUNTY DISTRICT COURT; and OKLAHOMA COURT OF CRIMINAL APPEALS, Defendants-Appellees. Notice: PLEASE REFER TO FEDERAL RULES OF APPELLATE PROCEDURE RULE 32.1 GOVERNING THE CITATION TO UNPUBLISHED OPINIONS. Subsequent History: US Supreme Court certiorari denied by Alexander v. Lucas, 128 S. Ct. 1486, 170 L. Ed. 2d 306, 2008 U.S. LEXIS 2294 (U.S., Mar. 3, 2008) Prior History: [**1] (D.C. No. CV-06-1386-HE). (W.D. Okla.). Alexander v. Lucas, 2007 U.S. Dist. LEXIS 26043 (W.D. Okla., Apr. 9, 2007) Core Terms district court, post-conviction, invalidity, state court Case Summary Procedural Posture Plaintiff state prisoner appealed from the United States District Court for the Western District of Oklahoma, which dismissed his 42 U.S.C.S. § 1983 suit against defendants, state judges and their respective courts. The prisoner argued that the Oklahoma courts incorrectly applied state law to preclude consideration of his petition for postconviction relief, thus depriving him of his constitutional right to due process. Overview The prisoner's complaint recounted and reargued the claims for relief underlying his state petition for postconviction relief. The district court dismissed the complaint as barred by Heck v. Humphrey for improperly using 42 U.S.C.S. § 1983 as a vehicle to challenge the validity of a conviction. The magistrate also stated that, to the extent the prisoner's suit could be construed as challenging an unfavorable state court decision, such a suit was foreclosed under the Rooker-Feldman doctrine. Acknowledging the ambiguity of the prisoner's complaint, the court affirmed the district court's dismissal. The prisoner acknowledged that his suit sought review and rejection of the Oklahoma state courts' judgments regarding his postconviction petitions for relief. In essence, he asked the court to vacate the state courts' dismissal of his petition and order a rehearing. The court ruled that neither it nor the district court had jurisdiction to do so. Because the appeal failed to state a claim on which relief could be granted, the court assessed, for purposes of 28 U.S.C.S. § 1915(g), one strike in addition to the strike assessed by the district court. Outcome The court affirmed the district court's dismissal and dismissed the appeal. LexisNexis® Headnotes EXHIBIT A Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 1 of 106 Page 2 of 4 Civil Rights Law > Protection of Rights > Section 1983 Actions > Scope HN1[] Protection of Rights, Section 1983 Actions If judgment in favor of a prisoner plaintiff in a 42 U.S.C.S. § 1983 damages suit would necessarily imply the invalidity of his conviction or sentence, then the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated. Civil Procedure > ... > Preclusion of Judgments > Full Faith & Credit > Rooker- Feldman Doctrine HN2[] Full Faith & Credit, Rooker-Feldman Doctrine Under the Rooker-Feldman doctrine, federal district courts have no jurisdiction to consider suits that amount to appeals of state-court judgments. The doctrine applies to cases brought by state- court losers complaining of injuries caused by state-court judgments rendered before the federal district court proceedings commenced and inviting district court review and rejection of those judgments. Counsel: For ALVIN LYNN ALEXANDER (# 84116), Plaintiff - Appellant: Alvin Lynn Alexander, Lexington, OK. Judges: Before LUCERO, HARTZ, and GORSUCH, Circuit Judges. Opinion by: Neil M. Gorsuch Opinion [*146] ORDER AND JUDGMENT * *After examining appellant's brief and the appellate record, this panel has determined unanimously that oral argument would not materially assist the determination of this appeal. See Fed. R. App. P. 34(a)(2) and 10th Cir. R. 34.1(G). The Alvin Lynn Alexander, a state prisoner in Oklahoma, claims that the Oklahoma state courts acted unconstitutionally in applying procedural bars under state law to preclude Mr. Alexander's petition for post-conviction relief, and he seeks declaratory and injunctive relief by way of 42 U.S.C. § 1983. The district court dismissed Mr. Alexander's action for lack of jurisdiction, holding that Mr. Alexander's suit is either an improper Section 1983 [**2] suit because it seeks to invalidate the underlying conviction, or it is barred by the Rooker-Feldman doctrine because it seeks direct review of a state court's final judgment. For substantially the same reasons expressed by the district court, we affirm the dismissal of Mr. Alexander's suit. * * * In 1995, Mr. Alexander pled guilty to a charge of second degree murder in the District Court of Cleveland County, Oklahoma, and was sentenced to fifty years' imprisonment. Although Mr. Alexander did not appeal his conviction, he has, while incarcerated, submitted several petitions for post-conviction relief in Oklahoma state court, all of which have been denied. In the most recent state court petition, Mr. Alexander argued that: (1) the trial court lacked jurisdiction to convict him because the district attorney failed to plead and prove the felony DUI conviction underlying the felony-murder charge on which Mr. Alexander was convicted; (2) the district court failed to make a determination of Mr. Alexander's competency to enter a [*147] plea; and (3) the district court therefore lacked jurisdiction to accept Mr. Alexander's plea. The District Court of Cleveland County denied Mr. Alexander's petition [**3] for relief, citing Oklahoma's Post-Conviction Procedure Act, Okla. Stat. tit. 22 § 1080 et seq., as well as state court precedent interpreting that Act, which preclude petitions for post-conviction relief based on arguments that could have been, but were not, raised on direct appeal. The Oklahoma case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 259 Fed. Appx. 145, *145; 2007 U.S. App. LEXIS 29745, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 2 of 106 Page 3 of 4 Court of Criminal Appeals affirmed the district court's judgment on the same grounds. Unsuccessful in seeking relief from the Oklahoma state courts, Mr. Alexander brought suit in federal court pursuant to 42 U.S.C. § 1983, naming as defendants the judges presiding over his trial court and appellate proceedings, as well as their respective courts. In his complaint, Mr. Alexander argues that the Oklahoma courts incorrectly applied state law to preclude consideration of his petition for post-conviction relief, thus depriving him of his constitutional right to due process. Along the way, Mr. Alexander's complaint also recounts and re-argues the claims for relief underlying his state petition. The case was referred to a magistrate judge for initial consideration, pursuant to 28 U.S.C. § 636(b)(1)(B),(C). The magistrate judge construed Mr. Alexander's suit as essentially attacking the constitutionality, [**4] and thus validity, of his conviction. As such, the magistrate recommended that the district court dismiss the case, pursuant to Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364, 129 L. Ed. 2d 383 (1994), for improperly using Section 1983 as a vehicle to challenge the validity of a conviction. In a footnote, the magistrate also stated that, to the extent Mr. Alexander's suit can be construed as challenging an unfavorable state court decision (referring to the decision on Mr. Alexander's most recent post-conviction relief petition), such a suit is foreclosed under the Rooker-Feldman doctrine. See Jan. 19, 2007, Report and Recommendation. The district court accepted the magistrate judge's recommendation and dismissed the case, stating that it was barred either under Heck or the Rooker-Feldman doctrine, depending on how the suit is construed. See Apr. 9, 2007, Dist. Ct. Order. Mr. Alexander filed a timely notice of appeal. * * * Affording solicitous consideration to Mr. Alexander's pro se court filings, as we are bound to do,see Van Deelen v. Johnson, 497 F.3d 1151, 1153 n.1 (10th Cir. 2007), we acknowledge the ambiguity of Mr. Alexander's complaint before the district court. At some points, the complaint seems to focus on [**5] the constitutionality and validity of the Oklahoma state courts' application of procedural bars to Mr. Alexander's post-conviction petitions for relief. See generally Dec. 15, 2006, Complaint. At other points, it seems to contest the constitutionality and validity of the conviction itself. See id. We need not conclusively determine the actual nature of Mr. Alexander's complaint for, construed either way, we are constrained to affirm the district court's dismissal. If Mr. Alexander's suit is meant to directly attack the validity of his conviction, then we must dismiss the suit as an improper use of Section 1983. In Heck, the Supreme Court stated that, HN1[] if judgment in favor of the prisoner plaintiff in a Section 1983 damages suit "would necessarily imply the invalidity of his conviction or sentence[, then] the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated." 512 U.S. at 487;see also Edwards v. Balisok, 520 U.S. 641, 648, 117 S. Ct. 1584, [*148] 137 L. Ed. 2d 906 (1997) (extending the rule in Heck to Section 1983 claims that, like Mr. Alexander's, seek declaratory relief). In his complaint, Mr. Alexander makes a number of arguments that would, if accepted [**6] by a court, clearly indicate the invalidity of his conviction. For example, Mr. Alexander argues that the state trial court never had jurisdiction to accept a plea and enter a judgment of conviction. Moreover, Mr. Alexander has never demonstrated that his conviction has already been invalidated. As such, Mr. Alexander's suit, construed in this way, has no proper basis as a Section 1983 claim. Mr. Alexander, however, argues emphatically in his brief on appeal that his suit does not challenge the validity of his conviction but instead only challenges the Oklahoma courts' application of procedural bars to dismiss his post-conviction petitions for relief. Such an interpretation of his complaint is confirmed in part by the complaint's request for relief, which expressly seeks only a declaration that the state courts' review procedure is unconstitutional and an injunction ordering a re- hearing on his post-conviction petition and ordering the courts to comply with the Fourteenth Amendment. Nowhere does Mr. Alexander 259 Fed. Appx. 145, *147; 2007 U.S. App. LEXIS 29745, **3 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 3 of 106 Page 4 of 4 specifically ask for the court to declare his conviction unconstitutional or invalid, even if his complaint includes arguments that seek to demonstrate such invalidity. If we accept [**7] Mr. Alexander's contention on appeal, we must agree with him that his suit is not precluded under Heck or its progeny. But construed in this way, Mr. Alexander's suit must be dismissed on the other grounds stated by the district court - namely, pursuant to the Rooker-Feldman doctrine. HN2[] Under this doctrine, federal district courts have no jurisdiction to consider suits "that amount to appeals of state-court judgments." Bolden v. City of Topeka, 441 F.3d 1129, 1139 (10th Cir. 2006). As the Supreme Court has stated, the doctrine applies to "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the [federal] district court proceedings commenced and inviting district court review and rejection of those judgments." Exxon Mobil Corp. v. Saudi Basic Indus., Corp., 544 U.S. 280, 284, 125 S. Ct. 1517, 161 L. Ed. 2d 454 (2005).1 Mr. Alexander readily acknowledges that his suit seeks review and rejection of the Oklahoma state courts' judgments regarding his post-conviction petitions for relief. In essence, he asks that we vacate the state courts' dismissal of his petition and order a re-hearing. Neither we nor the district court have jurisdiction to do so. The only federal review [**8] that Mr. Alexander can seek is by writ of certiorari to the Supreme Court. See Exxon Mobil, 544 U.S. at 285-86;28 U.S.C. § 1257. We are therefore bound to affirm the district court's dismissal even if we construe Mr. Alexander's complaint exactly as he contends. 1 We note that the scope of the Rooker-Feldman doctrine has been clarified in recent years and that we no longer apply it unless the federal suit commenced after the state court appeals process had run its full course. See Guttman v. Khalsa, 446 F.3d 1027, 1031-32 (10th Cir. 2006). In Oklahoma, the Court of Criminal Appeals is the state's highest court for criminal matters. See Okla. Const. art. 7 § 4;Okla. Stat. tit. 20 § 40. Its judgment on Mr. Alexander's appeal was entered on November 21, 2006, and Mr. Alexander filed his complaint in federal court on December 15, 2006. As such, Mr. Alexander's suit clearly falls within the scope of Rooker- Feldman. * * * Because Mr. Alexander's appeal fails to state a claim on which relief may be granted, we assess, for purposes of 28 U.S.C. § 1915(g), one strike in addition to [*149] the strike assessed by the district court. We note that the district court granted Mr. Alexander's request to proceed [**9] in forma pauperis, but we wish to remind Mr. Alexander of his obligation to continue making partial payments until the entire filing fee for this appeal is paid. See id.§ 1915(a),(b). The appeal is dismissed. 2 ENTERED FOR THE COURT Neil M. Gorsuch Circuit Judge End of Document 2 In his brief on appeal, Mr. Alexander asks that a certificate of appealability be granted. Because a certificate of appealability is not necessary for a prisoner civil rights appeal, we need not consider that request. See, e.g., Lawson v. Engleman, 67 Fed. Appx. 524, 527 n.4 (10th Cir. 2003). 259 Fed. Appx. 145, *148; 2007 U.S. App. LEXIS 29745, **6 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 4 of 106 Positive As of: October 8, 2021 1:53 AM Z Cochran v. City of Wichita United States District Court for the District of Kansas September 26, 2018, Decided; September 26, 2018, Filed Case No. 18-1132-JWB Reporter 2018 U.S. Dist. LEXIS 165825 *; 2018 WL 4637237 MICHAEL T. COCHRAN, Plaintiff, v. CITY OF WICHITA, et al., Defendants. Subsequent History: Affirmed by Cochran v. City of Wichita, 2019 U.S. App. LEXIS 19455 (10th Cir. Kan., June 28, 2019) Prior History:Cochran v. City of Wichita, 2018 U.S. Dist. LEXIS 94175 (D. Kan., June 5, 2018) Core Terms allegations, ordinance, camping, motion to dismiss, deprivation, constitutional right, statute of limitations, rights, homeless, shelter, tent, fail to state a claim, belongings, violates, notice, conspiracy, moped, subject matter jurisdiction, complaint alleges, conclusory, conspired, enact, savings, theft, substantially similar, prior complaint, post-deprivation, pertaining, questioned, municipal Counsel: [*1] Michael T. Cochran, Plaintiff, Pro se. Judges: JOHN W. BROOMES, UNITED STATES DISTRICT JUDGE. Opinion by: JOHN W. BROOMES Opinion MEMORANDUM AND ORDER This case comes before the court on Defendants' motion to dismiss (Doc. 24). The motion has been fully briefed and is ripe for decision. (Docs. 26, 27, 30, 31.) Defendants' motion is GRANTED for the reasons stated herein. I. Facts and Procedural History Plaintiff is homeless and proceeding pro se in this action. Plaintiff brings this action pursuant to 42 U.S.C. § 1985. Plaintiff's complaint alleges that Defendants, members of the Wichita City Council and several Wichita Police Department officers, conspired to enact Chapter 5.20 of the City Code which prohibits camping on public property. Section 5.20.020 states in pertinent part: "Unlawful Camping. It is unlawful and a public nuisance for any person or persons to camp in or upon any public property or public right of way, unless such person or persons have been granted a temporary permit allowing such activity as set forth in Section 5.20.040 of this chapter, or the individual or individuals are deemed homeless and there are no appropriate shelters available for them." (Doc. 30, Exh. 1 at 6.) The applicable camping code sections were enacted "to maintain streets, parks [*2] and other public property and areas within the City of Wichita in a clean, sanitary and accessible condition and to adequately protect the health, safety and public welfare of the community...." (Id. at 5.)1 Plaintiff has not been charged with a violation of Chapter 5.20. Plaintiff alleges that he arrived in Wichita, Kansas, 1 The court takes judicial notice of Ordinance 49-515, which sets forth Chapter 5.20 of the City of Wichita Code. See Zimomra v. Alamo Rent-A-Car, Inc., 111 F.3d 1495, 1504 (10th Cir. 1997) (appropriate for a court to take judicial notice of a municipal code). Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 5 of 106 Page 2 of 10 in June 2015. In August, Plaintiff set up a tent with his belongings on the City of Wichita's ("City") property located at 6919 E. Osie Cir. Plaintiff did not observe any signs that stated that the property belonged to the City. Plaintiff was never told by anyone that he was trespassing or that camping was illegal on the property. On February 15-17, 2016, Plaintiff observed a white van parked outside his tent with a license plate number that began with "CNR." On February 19, 2016, Plaintiff returned to his tent and discovered that all of his property was missing. Plaintiff was forced to go to a shelter as a result. (Doc. 1 at 4-5.) On February 21, Plaintiff returned to the area where his campsite had been to look for evidence of who took his belongings. While at the E. Osie location, Plaintiff observed a tent with a "notice to vacate" sign that included a phone number [*3] for the Wichita Police Department's Homeless Outreach Team ("HOT Team"). Plaintiff returned to the winter shelter. On February 22, Plaintiff called the HOT Team line and spoke with Defendant Lisa Berg. Plaintiff asked if the HOT Team had taken his belongings. Berg asked Plaintiff where the belongings had been and then informed Plaintiff of the no camping ordinance. Berg allegedly told Plaintiff that they could take whatever they wanted from whomever they wanted to. Plaintiff told Berg that he didn't get a notice although there was a notice on another person's tent. Berg allegedly stated that if one person got notice then they all got notice. Berg then stated that she had no idea if they had removed any of his property. Plaintiff left his phone number with Berg so that she could check into his property claim but she did not call him back. (Doc. 1 at 5-7.) Based on a liberal reading of Plaintiff's complaint, Plaintiff assumes, based on the presence of the white van and the notice to vacate sign on a different tent, that his tent and belongings were taken or disposed of by an unknown member of the HOT Team. Due to the removal or theft of Plaintiff's tent and belongings, Plaintiff alleges [*4] that he was "forcefully interned" at the over-flow shelter until March 31 and then "forcibly interned" at the Union Gospel Mission until May 27, 2016, both under cruel and unusual conditions. (Doc. 1 at 8.) On the evening of May 26, Plaintiff stayed at the shelter and parked his moped in the parking lot. On May 27, Plaintiff went to the parking lot and his moped was gone. Plaintiff reported the theft to the Wichita police. Plaintiff's complaint does not allege that an individual Defendant or City employee removed his moped. Plaintiff has not returned to the Mission. Plaintiff alleges that he lost his job due to the theft of his moped.2 (Doc. 1 at 8.) On November 15, 2016, Defendant Nate Schwiethale, an officer with the HOT Team, was responding to a complaint about someone sleeping outside in an area in downtown Wichita. Schwiethale approached Plaintiff and questioned him regarding the complaint. Plaintiff accused Schwiethale of taking his property. Plaintiff alleges that Schwiethale stated that Plaintiff would not be arrested and that he was there to help Plaintiff. Schwiethale allegedly admitted to the use and possession of a white van for the HOT Team and stated that the police can [*5] take anything they want. (Doc. 1 at 9-10.) On June 5, 2017, Plaintiff filed a lengthy complaint in this court asserting numerous claims against several defendants. (See Case No. 17-CV-1127, Doc. 1.) Plaintiff's complaint included claims against the same Defendants named in this action. Plaintiff also made similar allegations of a conspiracy in enacting the no camping ordinance and violations of his constitutional rights. (See id.) Magistrate Judge Birzer determined that Plaintiff's complaint failed to comply with Fed. R. Civ. P. 8 and ordered Plaintiff to file an amended complaint that complied with the rule or face dismissal. Plaintiff filed an amended complaint that was 207 pages long and raised the issues discussed herein in addition to other allegations and claims against several other government officials. (See Case No. 17-CV-1127, Doc. 15.) Judge Melgren dismissed Plaintiff's amended complaint, without prejudice, for failing to comply with Rule 8. (See Case No. 17- 2 As best the court can determine from the complaint, Plaintiff's logic is that all the foregoing calamities, most of which did not involve a Defendant or City Employee, give rise to claims against the Defendants because the alleged enforcement of the disputed ordinance is the event that somehow set all these events in motion. 2018 U.S. Dist. LEXIS 165825, *2 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 6 of 106 Page 3 of 10 CV-1127, Doc. 21.) Plaintiff's complaint in this case alleges a violation of 42 U.S.C. § 1985 due to Defendants' alleged conspiracy to enact the camping ordinance. Plaintiff further alleges that the camping ordinance deprives him of various rights under the [*6] First, Fourth,Fifth,Sixth,Eighth,Ninth and Fourteenth Amendments to the Constitution. Plaintiff contends that he has a constitutional right to be homeless. Plaintiff alleges that all Defendants conspired to enact the ordinance, deprived him of his property and forcibly interned him at the shelter. Defendants have now all moved to dismiss. Defendants contend that Plaintiff's claims are subject to dismissal under Rules 12(b)(1) and 12(b)(6). II. Standards Under Rule 12(b)(1) "Different standards apply to a motion to dismiss based on lack of subject matter jurisdiction under Rule 12(b)(1) and a motion to dismiss for failure to state a claim under Rule 12(b)(6)."Muscogee (Creek) Nation v. Pruitt, 669 F.3d 1159, 1167 (10th Cir. 2012). When the court is faced with motions for dismissal relying on both Rule 12(b)(1) and 12(b)(6), the court must first determine that it has subject matter jurisdiction over the controversy before reviewing the merits of the case under Rule 12(b)(6). Bell v. Hood, 327 U.S. 678, 682, 66 S. Ct. 773, 90 L. Ed. 939 (1946). Because federal courts are courts of limited jurisdiction, a presumption exists against jurisdiction, and "the burden of establishing the contrary rests upon the party asserting jurisdiction." Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377, 114 S. Ct. 1673, 128 L. Ed. 2d 391 (1994). Therefore, the court will first review the challenge to subject matter jurisdiction. "Motions to dismiss for lack of subject matter jurisdiction generally take one of two forms: (1) a facial attack on the sufficiency of the complaint's allegations as to [*7] subject matter jurisdiction; or (2) a challenge to the actual facts upon which subject matter jurisdiction is based." City of Albuquerque v. U.S. Dep't of Interior, 379 F.3d 901, 906 (10th Cir. 2004) (internal citations omitted). If the motion challenges the sufficiency of the complaint's jurisdictional allegations, such as in this case, the court must accept all such allegations as true. Holt v. United States, 46 F.3d 1000, 1002 (10th Cir. 1995). If there is a challenge to the actual facts, the court has discretion to allow affidavits and other documents to resolve disputed facts.Id. at 1003.In this matter, the court has only considered the ordinance, which may be considered on a motion to dismiss as it is a municipal law and referenced in Plaintiff's complaint. See Zimomra, 111 F.3d at 1504. In order to withstand a motion to dismiss for failure to state a claim, a complaint must contain enough allegations of fact to state a claim to relief that is plausible on its face. Robbins v. Oklahoma, 519 F.3d 1242, 1247 (10th Cir. 2008) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 127 S. Ct. 1955, 1974, 167 L. Ed. 2d 929 (2007)). All well-pleaded facts and the reasonable inferences derived from those facts are viewed in the light most favorable to Plaintiff. Archuleta v. Wagner, 523 F.3d 1278, 1283 (10th Cir. 2008). Conclusory allegations, however, have no bearing upon the court's consideration. Shero v. City of Grove, Okla., 510 F.3d 1196, 1200 (10th Cir. 2007). III. Analysis a. Subject Matter Jurisdiction Article III of the Constitution limits federal courts' jurisdiction to certain cases and controversies. Clapper v. Amnesty Int'l USA, 568 U.S. 398, 408, 133 S. Ct. 1138, 1146, 185 L. Ed. 2d 264 (2013). Plaintiff must establish standing in order [*8] to invoke this court's jurisdiction. Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61, 112 S. Ct. 2130, 2136, 119 L. Ed. 2d 351 (1992). A court reviews standing for claims that seek both retrospective relief and prospective relief. See Dias v. City & Cty. of Denver, 567 F.3d 1169, 1176-78 (10th Cir. 2009). To establish standing, there must be an "injury in fact"; Plaintiff must show a causal 2018 U.S. Dist. LEXIS 165825, *5 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 7 of 106 Page 4 of 10 connection between the injury and the conduct complained of; and it must be likely that Plaintiff's injury will be "redressed by a favorable decision." Lujan, 504 U.S. at 560-61;see also D.L.S. v. Utah, 374 F.3d 971, 974 (10th Cir. 2004). Under the "injury in fact" prong, Plaintiff's injury "must be actual or imminent, not conjectural or hypothetical." D.L.S, 374 F.3d at 974. "Allegations of possible future injury do not satisfy the injury in fact requirement, though a plaintiff need not expose himself to actual arrest or prosecution to be entitled to challenge a statute that he claims deters the exercise of his constitutional rights." Initiative & Referendum Inst. v. Walker, 450 F.3d 1082, 1087- 88 (10th Cir. 2006) (internal quotation marks and citations omitted). Defendants argue that Plaintiff does not have standing because he has not been charged with a violation of the ordinance, he has not alleged that he was forced into a shelter to avoid a citation or that he was denied a camping permit. (Doc. 30 at 7.) Plaintiff responds that he has sufficiently alleged standing in that his property was taken without notice or due process. (Doc. [*9] 31 at 8.) Liberally construing his complaint, Plaintiff alleges that he has been detained by the HOT Team and questioned because of camping in violation of the ordinance. (Doc. 1 at 9-10.) Plaintiff's complaint further alleges that as a result of his status as a homeless person he is subject to criminal punishment for violating the camping ordinance if there are beds available at the shelter. (Id. at 12, 14.) Plaintiff's complaint seeks both injunctive relief and damages for alleged constitutional violations. "To establish standing to seek prospective relief, a plaintiff must show a continuing injury; standing for retrospective relief can be based on past injuries." Dias v. City & Cty. of Denver, 567 F.3d 1169, 1176 (10th Cir. 2009). "When a plaintiff challenges the validity of a criminal statute under which he has not been prosecuted, he must show a 'real and immediate threat' of his future prosecution under that statute to satisfy the injury in fact requirement." D.L.S., 374 F.3d at 974 (citing Faustin v. City and County of Denver, Colo., 268 F.3d 942, 948 (10th Cir. 2001)).3 Due to Plaintiff's allegations regarding encounters with the HOT Team and his continued status as a homeless individual in the city, the court finds that Plaintiff has standing to seek prospective relief. The complaint alleges that other homeless campers have received notices to vacate the [*10] area in which Plaintiff camps. He also alleges that he has had contact with HOT Team members who indicate an intent to continue enforcing the ordinance in the future. (Doc. 1 at 9-10.) The court further finds that Plaintiff has standing to assert claims for his alleged injuries that occurred in the past. Therefore, Defendants' motion to dismiss on the basis that Plaintiff's complaint lacks subject matter jurisdiction is denied. b. Statute of Limitations Defendants assert that several claims are barred by the statute of limitations and that Plaintiff's filing of his previous complaint in Case No. 17-CV-1127 did not toll the statute of limitations. Plaintiff argues that the filing of his previous action tolled the statute of limitations and, in any event, the statute of limitations did not begin to run until his moped was stolen. (Doc. 31 at 9-10.) The applicable statute of limitations in §§ 1983 and 1985 actions is determined from looking at the appropriate Kansas statute of limitations. See Hardin v. Straub, 490 U.S. 536, 538, 109 S. Ct. 1998, 2000, 104 L. Ed. 2d 582 (1989).In Kansas, K.S.A. § 60-513(a), governing personal injury actions, is the application statute of limitations for claims under 42 U.S.C. § 1983 and § 1985.Brown v. Unified School Dist. 501, Topeka Public Schools, 465 F .3d 1184, 1188 (10th Cir. 2006). 3 The government cites to various opinions, outside of the Tenth Circuit, to argue that standing to establish a violation of an anti-camping statute can only be met in certain ways. (Doc. 30 at 6-7.) The Tenth Circuit, however, has set forth standing requirements to challenge municipal laws. This is the applicable standard and the court is not persuaded that a different standard would apply due to the content of the particular municipal law. 2018 U.S. Dist. LEXIS 165825, *8 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 8 of 106 Page 5 of 10 The accrual of Plaintiff's claim, however, is a question of federal [*11] law. Mondragón v. Thompson, 519 F.3d 1078, 1082 (10th Cir. 2008). Plaintiff's claim accrues when he knows, or should know, that his rights have been violated. Kripp v. Luton, 466 F.3d 1171, 1175 (10th Cir. 2006).With respect to a conspiracy claim, the statute of limitations "runs separately from each overt act of the conspiracy that allegedly caused injury." O'Connor v. St. John's Coll., 290 F. App'x 137, 141 (10th Cir. 2008). Therefore, the court will review all alleged conduct to determine whether it is barred by the statute of limitations. Plaintiff's claims are timely if the acts alleged to have violated his rights occurred within two years of filing his complaint or if the claims have been tolled under Kansas law. Plaintiff's complaint alleges the following acts: 1) passage of the ordinance in 2013; 2) removal of his tent and items on February 19, 2016; 3) a phone conversation with Officer Berg on February 22, 2016; 4) theft of his moped on May 26, 2016; and 5) an interaction with Schwiethale on November 15, 2016. Defendants assert that the only allegations that are timely are the theft of his moped and an interaction with Schwiethale. Plaintiff's complaint was filed on May 9, 2018. Under Kansas law, however, the savings statute will toll the statute of limitations if the requirements set forth in K.S.A. § 60-518 have been satisfied. Taylor v. Casey, 182 F. Supp. 2d 1096, 1102 (D. Kan. 2002). Section 60-518 requires the following: 1) the [*12] first action was commenced within due time, 2) the first action failed "otherwise than upon the merits," 3) and the new action was commenced within six months of the failure. Id. The two actions must also be substantially similar. Estate of Hammers v. Douglas Cty., Kan. Bd. of Comm'rs, 303 F. Supp. 3d 1134, 1153 (D. Kan. 2018). Case No. 17-CV-1127 was filed on June 5, 2017. Even if the remaining elements are established, section 60-518 would not save Plaintiff's claim pertaining to the passage of the ordinance in 2013 as it was clearly untimely in 2017. Under federal law, it is the overt act that begins the running of the statute and not the theft of the moped as asserted by Plaintiff. See O'Connor, 290 F. App'x at 141. Therefore, this claim is barred by the statute of limitations. The other four overt acts, however, all occurred within two years of the filing of the original complaint.4 The remaining elements are satisfied because the action was not dismissed on the merits and the instant action was filed within six months of the dismissal. Defendants assert that the savings statute does not save these claims because the two actions are not substantially similar. See Estate of Hammers, 303 F. Supp. 3d at 1153. Defendants argue that the claims are not substantially similar as there are "fewer defendants and the claims asserted are different in nature." (Doc. 30 at [*13] 9.) Defendants, however, fail to explain how the claims are different in nature. A review of the prior complaint shows that Plaintiff's allegations pertaining to the camping ordinance are contained therein. The prior complaint also included all of the defendants that are in this action. The prior complaint, however, had significantly more defendants and claims than are contained in the current complaint. Plaintiff argues that Defendants' logic would simply have him refile his prior complaint which would clearly be subject to dismissal. (Doc. 31 at 10.) The court finds that the claims stated in this action are substantially similar to claims raised in the prior complaint. The differences in the complaints are due to Plaintiff reducing the number of claims and defendants named in the present action. The court finds that the elimination of claims and defendants does not lead to the conclusion that the actions are not substantially similar; they are similar as to the claims and defendants that Plaintiff has elected to pursue. By contrast, it seems rather ridiculous to conclude that a mere reduction in claims and defendants, while no new claims or new parties are added, would preclude application [*14] of the savings statute with respect to the claims and defendants in the new case. See Marten v. Godwin, No. 08-4031-EFM, 2009 U.S. Dist. LEXIS 4 The court notes that service was not completed on the defendants in the prior action because the court stayed service. Therefore, the delay of service was not due to inaction on Plaintiff's part. 2018 U.S. Dist. LEXIS 165825, *10 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 9 of 106 Page 6 of 10 71023, 2009 WL 2475257, at *2-3 and n. 16 (D. Kan. Aug. 12, 2009) (discussing cases) ("Furthermore, as a practical matter, such an interpretation is illogical. As pointed out by William Westerbeke and Stephen McAllister in Survey of Kansas Tort Law: Part 1,49 U. Kan. L. Rev. 1037, 1136 (June 2001), 'requiring the continuation of litigation against the individual defendants even though the plaintiff no longer believes the claim against him is legitimate conditions the use of the savings clause upon court-ordered malicious prosecution.'") Therefore, with the exception of the 2013 overt act of passing the camping ordinance, Plaintiff's remaining allegations are not barred by the statute of limitations. c.Section 1985 - All Defendants Defendants move to dismiss Plaintiff's claims pursuant to section 1985 on the basis that the allegations fail to state a claim upon which relief can be granted. Plaintiff's complaint alleges that Defendants conspired to violate his constitutional rights by enacting the ordinance, depriving him of his property and depriving him of other constitutional rights as a result of the ordinance. Section 1985(3) provides a remedy for a conspiracy to violate a person's [*15] civil rights. O'Connor, 290 F. App'x at 141.The elements of a section 1985 claim are: "(1) a conspiracy; (2) to deprive plaintiff of equal protection or equal privileges and immunities; (3) an act in furtherance of the conspiracy; and (4) an injury or deprivation resulting therefrom." Tilton v. Richardson, 6 F.3d 683, 686 (10th Cir. 1993), cert. denied,510 U.S. 1093, 114 S. Ct. 925, 127 L. Ed. 2d 218 (1994). With respect to allegations of a conspiracy, the Tenth Circuit requires a plaintiff to allege a sufficient factual basis to support the existence of an agreement and concerted action between the co-conspirators. Abercrombie v. City of Catoosa, 896 F.2d 1228, 1230-31 (10th Cir. 1990)."Section 1985(3) conspiracy claims cannot stand on 'vague and conclusory allegations'; but rather, 'must be pled with some degree of specificity.'" O'Connor, 290 F. App'x at 141. Plaintiff argues that he has alleged that the concerted action is the drafting and passing of the ordinance. (See Doc. 31 at 14.) As discussed, any action based on this alleged conduct is barred by the statute of limitations. Plaintiff's allegations do not contain any instances of alleged concerted action or agreement to deprive Plaintiff of his constitutional rights after 2013. Rather, Plaintiff's complaint merely includes conclusory statements that Defendants conspired to violate his rights. Therefore, Plaintiff's claims against Defendants for conspiring together to deprive Plaintiff [*16] of his constitutional rights fail to state a claim. d.Section 1983 - City Council Members and Mayor Although Plaintiff does not specifically identify 42 U.S.C. § 1983 in his complaint, Plaintiff's complaint clearly alleges that all Defendants violated his constitutional rights. Section 1983 is the statute that provides a "remedy for constitutional violations committed by state officials." Gallagher v. Neil Young Freedom Concert, 49 F.3d 1442, 1447 (10th Cir. 1995). Defendants move for dismissal of all Section 1983 claims on the basis that Plaintiff has failed to state a claim. Plaintiff's allegations pertaining to the city council members and the mayor all state as follows: Plaintiff claims that City of Wichita, City Council Member District I, Lavonta Williams5; did under color of law and/or in her individual capacity, did with malicious intent, and/or wanton misconduct, and/or with reckless disregard violated Plaintiff's rights under the U.S. Constitution by conspiring with other members of the city council and members of the Wichita Police Department and then voting for on or about June 21, 2013 for the passage of Wichita City Ordinance, Chapter 5.20 Camping 5 Plaintiff's complaint sets forth a new section for each named Defendant. The allegations, however, pertaining to the city council members and the mayor are identical in each section. (See Doc. 1 at 17-41.) 2018 U.S. Dist. LEXIS 165825, *14 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 10 of 106 Page 7 of 10 on Public Property Without A Permit violating and depriving Plaintiff of rights under the following Amendments of the U. S. Constitution[.] (Doc. 1 at 17-18.) [*17] Clearly, the allegations surrounding these Defendants pertain to their actions in passing the ordinance back in June 2013. As Plaintiff's claims regarding that action are untimely and Plaintiff has failed to allege any actions taken by Defendants Williams, Meitzner, Clendenin, Blubaugh, Fry, Miller and Longwell after 2013, the Section 1983 claims against these Defendants are dismissed as barred by the statute of limitations. e.Section 1983 - Defendants Stull and Nienstedt Defendants move for dismissal of the claims against Wichita Police Officers Stull and Nienstedt on the basis that Plaintiff's complaint wholly lacks any factual allegations regarding these Defendants. The court agrees. Plaintiff's complaint alleges that these officers conspired to enact the camping ordinance, seized his belongings and moped6, and forced him to stay in the shelter. (Doc. 1 at 50-53; 57-61.) The allegation regarding the enacting of the ordinance is barred by the statute of limitations. The remaining allegations are all conclusory. It is clear by the facts alleged in the complaint that Plaintiff has failed to allege any actual conduct by Defendants Stull and Nienstedt. In order to state a claim against a public official, a plaintiff [*18] may not rely on the theory of respondeat superior for the actions of co-workers or subordinates. Rather, Plaintiff must plead facts 6 Plaintiff's conclusory claims are identical against each named Defendant. (Doc. 1 at 50-53; 57-61.) However, the facts alleged do not state any allegations of specific conduct regarding these defendants and the seizure of Plaintiff's property. The complaint implies that some member of the HOT Team seized Plaintiff's tent but there is no allegation of who actually removed the tent. Plaintiff appears to blame the theft of his moped on the HOT Team because he was forced to go to the Shelter but not because a member of the HOT Team actually seized his moped. showing that Stull and Nienstedt, through their own individual actions, have violated the Constitution. Ashcroft v. Iqbal, 556 U.S. 662, 676, 129 S. Ct. 1937, 1948, 173 L. Ed. 2d 868 (2009).Plaintiff's complaint must "make clear exactly who is alleged to have done what to whom, to provide each individual with fair notice as to the basis of the claim against him or her." Robbins v. Oklahoma, 519 F.3d 1242, 1250 (10th Cir. 2008) (citing Twombly, 127 S. Ct. at 1970-71 n. 10). Plaintiff's claims against Stull and Nienstedt do not allege any actions that they have taken with respect to Plaintiff's rights. Therefore, Plaintiff's claims against Stull and Nienstedt must be dismissed. f. Defendant Berg Defendants move to dismiss claims against Officer Berg on the basis that they fail to state a claim and that she is entitled to qualified immunity. The sole facts pertaining to Defendant Berg revolve around a phone call between Berg and Plaintiff. In that call, Plaintiff alleges that Berg advised Plaintiff of the no camping ordinance, claimed that the City may take whatever they want and failed to call him back. (Doc. 1 at 6-7.) These allegations fail to state a claim. Although Berg allegedly stated that the City can take what it wants, there [*19] are no facts in the complaint that allege that Berg took Plaintiff's property. Moreover, Berg's failure to call Plaintiff, in and of itself, does not violate his constitutional rights nor does Plaintiff allege any cognizable injury due to Berg's actions. The court finds that the allegations in the complaint fail to state a claim under section 1983 against Defendant Berg. g. Defendant Schwiethale Defendants move to dismiss claims against Officer Schwiethale on the basis that they fail to state a claim and that Schwiethale is entitled to qualified immunity. With respect to Schwiethale's actions, the complaint alleges that Schwiethale questioned him early on the morning of November 15, 2016. 2018 U.S. Dist. LEXIS 165825, *16 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 11 of 106 Page 8 of 10 Plaintiff allegedly had permission to sleep on the property and Schwiethale had been dispatched to the area in response to a complaint about an individual sleeping on the property. Plaintiff claims that Schwiethale asked him questions on November 15 and on three other occasions. (Doc. 1 at 9-10.) Plaintiff was never arrested by Schwiethale or any other Wichita officer for a violation of the camping ordinance. Plaintiff alleges that Schwiethale's conduct violated his constitutional rights. Plaintiff's allegations [*20] clearly state that Schwiethale was investigating a report of someone sleeping in violation of the camping ordinance. "An officer can stop and briefly detain a person for investigative purposes if the officer has a reasonable suspicion supported by articulable facts that criminal activity may be afoot, even if the officer lacks probable cause." Cortez v. McCauley, 478 F.3d 1108, 1115 (10th Cir. 2007). Therefore, his actions did not violate Plaintiff's Fourth Amendment rights. Moreover, Plaintiff was not arrested nor has Plaintiff alleged any other actionable injury due to Schwiethale's questioning. Plaintiff's complaint fails to identify the circumstances of the other interactions with Schwiethale. Therefore, Plaintiff has failed to state a claim as the allegations do not establish a constitutional violation.7 h. City of Wichita Defendants also move for dismissal of Plaintiff's claims against the City and the claims against the individual City Defendants in their official capacity. Plaintiff responds that he has not brought any claims against the City and consents to the dismissal of the City from this action. (Doc. 28 at 53-54; 31 at 16-17). Plaintiff also does not oppose the dismissal of the official capacity claims against 7 Because Plaintiff's complaint fails to sufficiently allege a violation of his constitutional rights by the officers named in the complaint, the officers would also be entitled to qualified immunity. Pearson v. Callahan, 555 U.S. 223, 232, 129 S. Ct. 808, 816, 172 L. Ed. 2d 565 (2009). the individual Defendants. (Doc. [*21] 31 at 16- 17.) The court notes that Plaintiff is proceeding pro se. A court is to liberally construe a pro se Plaintiff's pleadings. Hall v. Bellmon, 935 F.2d 1106, 1109 (10th Cir. 1991). However, the court is not to assume a role of advocate or craft legal theories. Id. at 1110.Therefore, the court's role cannot be to force Plaintiff to proceed against the City to seek the relief that he is requesting in his complaint. Plaintiff has clearly stated that he is unopposed to dismissing the City from this action and refers to claims against the City as "nonexistent." (Doc. 31 at 17.) Therefore, Defendants' motion to dismiss the claims against the City is granted as uncontested.8 Alternatively, the court grants Defendants' motion to dismiss for the reasons stated in Defendants' memorandum. (Doc. 30 at 17-29.)9 With respect to the actions taken by the individual Defendants, the claims against the City are subject to dismissal as the court has determined that Plaintiff's complaint fails to allege that a state actor violated Plaintiff's constitutional rights. See Estate of Larsen v. Murr, 511 F.3d 1255, 1264 (10th Cir. 2008) ("without the predicate constitutional harm inflicted by an officer, no municipal liability exists.") Plaintiff's complaint also contends that the camping ordinance violates his rights [*22] under the First, Fourth,Fifth,Sixth,Eighth,Ninth and Fourteenth Amendments. (Doc. 1 at 10-16.) Plaintiff's allegations are wholly conclusory and fail to state a claim. Plaintiff's claims are based on his alleged constitutional right to be homeless. The Supreme Court has not held that there is a constitutional 8 The official capacity claims are subject to dismissal as they are redundant of any claims against the City. See, e.g., Stewart v. City of Prairie Vill., Kan., 904 F. Supp. 2d 1143, 1161 (D. Kan. 2012). 9 Plaintiff points out that Defendants' heading in section IX of their brief states that the ordinances do not violate "Defendant's" constitutional rights. (Doc. 31 at 17.) This is clearly a typographical error as the substance of the argument in the entire section discusses the sufficiency of Plaintiff's claims against the City. (Doc. 30 at 17-29.) 2018 U.S. Dist. LEXIS 165825, *19 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 12 of 106 Page 9 of 10 right to be homeless. Moreover, courts have not recognized the homeless as a suspect class. See Sanchez v. City of Fresno, 914 F. Supp. 2d 1079, 1108-09 (E.D. Cal. 2012) (discussing cases); Anderson v. Herbert, No. 2:13-CV-211, 2014 U.S. Dist. LEXIS 166371, 2014 WL 6769907, at *5 (D. Utah Dec. 1, 2014). This court declines to find that Plaintiff, as a homeless man, is a member of a suspect class. With respect to the allegations that the ordinance violates Plaintiff's constitutional rights, Plaintiff's allegations are conclusory. Although Plaintiff alleges that the ordinance violates his First Amendment rights, he fails to identify how the First Amendment applies to the conduct targeted by the ordinance. See Clark v. Community for Creative Non-Violence, 468 U.S. 288, 293 n. 5 104 S. Ct. 3065, 82 L. Ed. 2d 221 (1984) (it is a plaintiff's burden to identify how the First Amendment applies to conduct). Plaintiff's conclusory allegations regarding other constitutional violations meet a similar fate. Plaintiff merely restates the rights under those amendments and claims that the camping ordinance violates the same. That is not sufficient to state a claim. Twombly, 550 U.S. at 555, 127 S. Ct. at 1965. In [*23] Joel v. City of Orlando, 232 F.3d 1353 (11th Cir. 2000), the Eleventh Circuit upheld a no camping ordinance. The court held that the ordinance did not violate the Eighth Amendment by criminalizing involuntary behavior. Id. at 1362. The court reasoned that the Constitution allows the city to regulate where camping occurs and that it was not criminalizing homelessness because the city shelters had never reached capacity and never turned an individual away. See id. In cases that found a violation of the Eighth Amendment, the courts explicitly relied on the lack of shelter space and reasoned that the ordinances were criminalizing involuntary behavior. Id. The camping ordinance at issue does not criminalize involuntary behavior as an individual cannot be charged with a violation of the camping ordinance when there are no open beds in a shelter. Therefore, the camping ordinance specifically targets voluntary conduct and does not violate Plaintiff's Eighth Amendment rights.See id. Finally, Plaintiff claims that the ordinance is overly broad and unconstitutionally vague. Plaintiff, however, wholly fails to identify how it is overly broad or unconstitutionally vague. Therefore, Plaintiff's complaint fails to state a claim. i. Taking of Property Liberally construed, Plaintiff's complaint alleges that the [*24] City, presumably an unknown officer with the HOT Team, removed his tent and belongings without Due Process. Plaintiff's complaint fails to state this claim against the City because Plaintiff has failed to sufficiently allege that an officer or other City employee removed his property. Plaintiff's vague allegations regarding the white van seen two days prior to the removal of his tent do not sufficiently allege that a City officer removed his property. Nevertheless, even if Plaintiff's complaint could be construed to allege that an officer of the City removed Plaintiff's tent and belongings, Plaintiff's complaint fails to state a claim under federal law for the following reasons: 1) Plaintiff has failed to allege a municipal policy behind the removal of his property and 2) Plaintiff has failed to allege that he lacks an adequate remedy under state law. With respect to any removal or seizure of Plaintiff's property, Plaintiff has failed to allege a municipal policy that was the moving force behind the alleged deprivation. As the camping ordinance does not authorize such action, the ordinance cannot be the basis to establish a municipal policy. Rather, Plaintiff must allege a policy or [*25] custom of the City to deprive belongings without notice in order to state a claim. Larsen, 511 F.3d at 1264. Plaintiff has not done so. Moreover, although Plaintiff's complaint does not specifically allege who took action in removing the property, the law is well settled that Plaintiff must allege facts showing the lack of an adequate state remedy for the deprivation in order to state a Fourteenth Amendment claim for violation of due process.Gee v. Pacheco, 627 F.3d 1178, 1194 (10th Cir. 2010) (citing Hudson v. Palmer, 468 U.S. 517, 533, 104 S. Ct. 3194, 82 L. Ed. 2d 393 (1984)). "[A]n unauthorized intentional deprivation 2018 U.S. Dist. LEXIS 165825, *22 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 13 of 106 Page 10 of 10 of property by a state employee does not constitute a violation of the procedural requirements of the Due Process Clause of the Fourteenth Amendment if a meaningful post-deprivation remedy for the loss is available," and "the state's action is not complete until and unless it provides or refuses to provide a suitable post-deprivation remedy." Id. (quoting Hudson, 468 U.S. at 533).Kansas law provides post-deprivation remedies to individuals who believe they have suffered a tortious loss at the hands of state officials. Haynes v. Attorney General of Kan., No. 03-4209, 2005 U.S. Dist. LEXIS 24391, 2005 WL 2704956 at *5 (D. Kan. 2005). Plaintiff could have filed a claim for replevin, conversion, or a claim under the Kansas Tort Claims Act. Roman v. FNU LNU Unknown State & Local Officials, Barton Cty., Kan., No. 12-3065- SAC, 2012 U.S. Dist. LEXIS 75797, 2012 WL 1970384, at *4 (D. Kan. June 1, 2012). These procedures satisfy process and are adequate post- deprivation remedies for the harm alleged in Plaintiff's complaint. See id. Because Plaintiff's complaint does not allege that [*26] tort actions available under state law are an inadequate remedy, there is no constitutional deprivation of property without due process of law for purposes of the Fourteenth Amendment or § 1983. Pacheco v. Wagnon, 2008 U.S. Dist. LEXIS 23762, 2008 WL 755059 at *5 (D. Kan. 2008); Roman, 2012 U.S. Dist. LEXIS 75797, 2012 WL 1970384, at *4 ("when a plaintiff alleges deprivation of a property interest occurring as a result of 'a random, unauthorized act,' the Fourteenth Amendment's due process requirement is satisfied if the state provides an adequate post- deprivation remedy.") Nor is there any taking of property in violation of the Fifth Amendment.See City of Monterey v. Del Monte Dues at Monterey, Ltd., 526 U.S. 687, 714-15, 119 S. Ct. 1624, 1640- 41, 143 L. Ed. 2d 882 (1999);Wilson v. United States, 29 F. App'x 495, 496-97 (10th Cir. 2002). Plaintiff has not alleged a plausible constitutional deprivation of property claim. IV. Conclusion Defendants' motion to dismiss (Doc. 24) is GRANTED. Plaintiff's motion to deny/strike Defendants' motion to dismiss (Doc. 27) is DENIED AS MOOT. IT IS SO ORDERED this 26th day of September, 2018. /s/ John W. Broomes JOHN W. BROOMES UNITED STATES DISTRICT JUDGE End of Document 2018 U.S. Dist. LEXIS 165825, *25 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 14 of 106 Positive As of: October 8, 2021 1:52 AM Z Galbreath v. City of Oklahoma United States Court of Appeals for the Tenth Circuit June 11, 2014, Filed No. 12-6295 Reporter 568 Fed. Appx. 534 *; 2014 U.S. App. LEXIS 10824 **; 2014 WL 2598657 ALLEN GALBREATH, Plaintiff - Appellant, v. THE CITY OF OKLAHOMA CITY; KEVIN PARTON, Defendants - Appellees. Notice: PLEASE REFER TO FEDERAL RULES OF APPELLATE PROCEDURE RULE 32.1 GOVERNING THE CITATION TO UNPUBLISHED OPINIONS. Prior History: [**1] (D.C. No. 5:11-CV-01336- HE). (W.D. Okla.). Galbreath v. City of Okla., 2012 U.S. Dist. LEXIS 152652 (W.D. Okla., Oct. 24, 2012) Core Terms ordinance, district court, arrest, summary judgment, disorderly conduct, vagueness, unconstitutionally vague, municipal, alarm, as- applied, qualified immunity, exercises, declaratory, morning, cane, void-for-vagueness, ballet, grant summary judgment, reasonable person, adequate notice, fair notice, notice Case Summary Overview HOLDINGS: [1]-The district court erred in granting summary judgment to the city in an arrestee's action alleging that City of Oklahoma City, Okla., Ordinance No. 22210, § 30-81(b) (2003) was unconstitutionally vague as applied because a reasonable jury could conclude that the arrestee lacked fair notice that his conduct in the park could lead to criminal sanctions under the ordinance; [2]- Nothing in the plain language of the ordinance suggested that singing and performing choreographed ballet moves in the park with a 3- foot cane while wearing high heels would cause public alarm; [3]-The ordinance's plain language failed to give the arrestee notice that any public alarm caused by the morning exercises would be without justification; [4]-The ordinance lacked a scienter requirement, which could have mitigated the indefiniteness of the other terms when applied to the arrestee's conduct. Outcome Summary judgment reversed. LexisNexis® Headnotes Civil Procedure > Appeals > Summary Judgment Review > General Overview HN1[] Appeals, Summary Judgment Review When the case comes to the court of appeals from summary judgment, it recites the facts in the light most favorable to the non-moving party, resolving all factual disputes and reasonable inferences in his or her favor. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > General Overview Civil Procedure > Appeals > Summary Judgment Review > Standards of Review Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 15 of 106 Page 2 of 11 HN2[] Summary Judgment, Entitlement as Matter of Law The court of appeals reviews a district court's grant of summary judgment de novo, using the same standard applied by the district court pursuant to Fed. R. Civ. P. 56(a). Civil Procedure > Judgments > Summary Judgment > Evidentiary Considerations HN3[] Summary Judgment, Evidentiary Considerations The court of appeals must view facts in the light most favorable to the non-moving party, resolving all factual disputes and reasonable inferences in his or her favor. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > General Overview HN4[] Summary Judgment, Entitlement as Matter of Law Summary judgment shall be granted if there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law.Fed. R. Civ. P. 56(a). Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Materiality of Facts HN5[] Entitlement as Matter of Law, Materiality of Facts A fact is material if, under governing law, it could affect the outcome of the lawsuit. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Genuine Disputes HN6[] Entitlement as Matter of Law, Genuine Disputes A factual dispute is genuine if a rational jury could find in favor of the nonmoving party on the evidence presented. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > General Overview Civil Rights Law > Protection of Rights > Immunity From Liability > Defenses HN7[] Summary Judgment, Entitlement as Matter of Law At summary judgment, courts must grant qualified immunity unless the plaintiff meets a two-part burden to show (1) a reasonable jury could find facts supporting a violation of a constitutional right, which (2) was clearly established at the time of the defendant's conduct. Courts may exercise their sound discretion in deciding which of the two steps of the qualified immunity analysis should be addressed first in light of the circumstances in the particular case at hand. Civil Rights Law > ... > Section 1983 Actions > Scope > Government Actions HN8[] Scope, Government Actions Resolving 42 U.S.C.S. § 1983 claims against municipalities requires consideration of whether the city is responsible for harm caused by a constitutional violation. Governments > Local Governments > Ordinances & Regulations Governments > Legislation > Vagueness HN9[] Local Governments, Ordinances & Regulations 568 Fed. Appx. 534, *534; 2014 U.S. App. LEXIS 10824, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 16 of 106 Page 3 of 11 An as-applied challenge to an ordinance can give rise to municipal liability. Civil Rights Law > ... > Section 1983 Actions > Scope > Government Actions HN10[] Scope, Government Actions A city will not automatically be liable under 42 U.S.C.S. § 1983 if one of its employees happened to apply a constitutional policy in an unconstitutional manner. Civil Rights Law > ... > Section 1983 Actions > Scope > Government Actions HN11[] Scope, Government Actions Municipal entities may be subject to liability under 42 U.S.C.S. § 1983 if they make and enforce a law that is unconstitutional as applied. Criminal Law & Procedure > ... > Disruptive Conduct > Disorderly Conduct & Disturbing the Peace > General Overview Governments > Local Governments > Ordinances & Regulations HN12[] Disruptive Conduct, Disorderly Conduct & Disturbing the Peace Oklahoma City's disorderly conduct ordinance, Oklahoma City, Okla., Municipal Code § 30-81(b), reflects the official policy of the municipality. Official municipal policy includes the decisions of a government's lawmakers. Governments > Legislation > Vagueness HN13[] Legislation, Vagueness The question of whether a statute has been rendered unconstitutionally vague as applied is a question involving issues of law. Constitutional Law > ... > Case or Controversy > Constitutionality of Legislation > General Overview Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection HN14[] Case or Controversy, Constitutionality of Legislation To satisfy due process, a penal statute must define the criminal offense (1) with sufficient definiteness that ordinary people can understand what conduct is prohibited and (2) in a manner that does not encourage arbitrary and discriminatory enforcement. Governments > Local Governments > Ordinances & Regulations Governments > Legislation > Vagueness HN15[] Local Governments, Ordinances & Regulations For an as-applied vagueness challenge, the court of appeals must tether its analysis to the factual context in which the ordinance was applied. Criminal Law & Procedure > ... > Disruptive Conduct > Disorderly Conduct & Disturbing the Peace > Elements HN16[] Disorderly Conduct & Disturbing the Peace, Elements A person is guilty of disorderly conduct, a Class "a" offense, when such person causes public alarm without justification. City of Oklahoma City, Okla., Ordinance No. 22210, § 30-81(b) (2003). Constitutional Law > ... > Case or Controversy > Constitutionality of 568 Fed. Appx. 534, *534; 2014 U.S. App. LEXIS 10824, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 17 of 106 Page 4 of 11 Legislation > General Overview Governments > Local Governments > Ordinances & Regulations Governments > Legislation > Vagueness HN17[] Case or Controversy, Constitutionality of Legislation In evaluating the adequate notice element, the court of appeals must determine whether a reasonable person would have fair notice from the language of the ordinance that the particular conduct which he or she engaged in was punishable. In an as-applied challenge, a statute is unconstitutionally vague if it fails to put a defendant on notice that his or her conduct was criminal. For statutes involving criminal sanctions the requirement for clarity is enhanced. Governments > Legislation > Interpretation HN18[] Legislation, Interpretation "Alarm" defined as sudden fear or concern caused by the realization of danger or an impending setback. Governments > Legislation > Interpretation HN19[] Legislation, Interpretation "Justification" is defined as a lawful or sufficient reason for one's acts or omissions. Constitutional Law > ... > Case or Controversy > Constitutionality of Legislation > General Overview Criminal Law & Procedure > Criminal Offenses > Acts & Mental States > General Overview Governments > Legislation > Vagueness HN20[] Case or Controversy, Constitutionality of Legislation Fair notice concerns can be ameliorated by the fact that the challenged statute contains a scienter requirement. A scienter requirement may mitigate a criminal law's vagueness by ensuring that it punishes only those who are aware their conduct is unlawful. Counsel: For ALLEN GALBREATH, Plaintiff - Appellant: John Spencer Bryan, Bryan & Terrill Law, Tulsa, OK; Steven James Terrill, Bryan & Terrill Law, Tulsa, OK. For THE CITY OF OKLAHOMA CITY, Defendant - Appellee: Richard C. Smith, Esq., Office of Municipal Counselor, Litigation Division, Oklahoma City, OK; Jennifer M. Warren, City of Oklahoma City, Office of the Municipal Counselor, Oklahoma City, OK. For KEVIN PARTON, Defendant - Appellee: Stacey Felkner, Fenton Fenton Smith Reneau & Moon, Oklahoma City, OK; Susan Ann Knight, Manchester & Knight, PLLC, Oklahoma City, OK. Judges: Before GORSUCH, MATHESON, and BACHARACH, Circuit Judges. Opinion by: Scott M. Matheson, Jr. Opinion [*535] ORDER AND JUDGMENT* Allen Galbreath was arrested for disorderly conduct while performing his morning ballet exercises in an Oklahoma City park. He brought a civil rights action under 42 U.S.C. § 1983 against the arresting officer and the City, alleging the arrest lacked [**2] probable cause and the municipal ordinance was unconstitutionally vague. Each defendant moved for summary judgment, and Mr. *This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 568 Fed. Appx. 534, *534; 2014 U.S. App. LEXIS 10824, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 18 of 106 Page 5 of 11 Galbreath moved for declaratory judgment on his claims against the City. The district court denied Mr. Galbreath's motion and granted both defendants' motions, holding (1) the arresting officer had qualified immunity and (2) the disorderly conduct ordinance was not unconstitutionally vague as applied to Mr. Galbreath. Mr. Galbreath now appeals. Exercising jurisdiction under 28 U.S.C. § 1291, we affirm the first holding. As to the second, we reverse and remand. I.BACKGROUND A.Factual History1 Mr. Galbreath is a "former dancer with the Oklahoma Ballet." Aplt. Appx., Vol. I at 177. Because of a debilitating hip condition, Mr. Galbreath regularly performed ballet exercises as a form of "physical therapy" at Goodholm Park in Oklahoma City to improve his ambulatory function. Id. at 124, 177 n.1. [**3] In June 2010, Mr. Galbreath went to Goodholm Park to perform his morning physical therapy exercises. He wore "[o]versized gray pants, a fitted gray T-shirt, . . . a red bandanna," and "high-heel shoe[s]." Id. at 129. He also carried a walking cane roughly 3 feet in length and a large red handbag. Upon arriving at the park, Mr. Galbreath began singing and performing dance moves using his cane. Shortly thereafter, Mr. Galbreath fielded a call from a friend and began laughing loudly. See id. at 133, 288. A woman called 911 to report she was at the park with her grandchildren and concerned about a "man in high heels with a big stick and a purse." Id. at 152 (recording of 911 call).2 Officer Kevin Parton of the Oklahoma City Police Department responded to the 911 call. After arriving, he found Mr. Galbreath wearing high 1 HN1[] Because this case comes to us from summary judgment, we recite the facts "in the light most favorable to" the non-moving party, Mr. Galbreath, "resolving all factual disputes and reasonable inferences" in his favor. Cillo v. City of Greenwood Village, 739 F.3d 451, 461 (10th Cir. 2013). 2 Although the recording of the 911 call is garbled, the transcript states the caller thought Mr. Galbreath was "drunk." Aplt. Appx., Vol. I at 272. heels and carrying a cane. When the officer asked Mr. Galbreath what he was doing at the park, Mr. Galbreath explained that he was doing his "morning exercises" and demonstrated a short choreographed ballet sequence using his walking [**4] cane. Id. at 140, 288. According to Mr. Galbreath, Officer Parton "grabbed" Mr. Galbreath's arm, twisted it up "above [his] head to where it hurt" and escorted Mr. Galbreath to the police car. Id. at 134. Officer Parton searched Mr. Galbreath's red bag and found an air pistol. After handcuffing Mr. Galbreath as a "precautionary measure" and running a warrant check, Officer Parton learned that Mr. Galbreath had no outstanding arrest warrants or any criminal background. Id. at 160, 179. [*536] Officer Parton recounted that, save for two tennis players, the other people in the park had gathered by the playground equipment and were no longer involved in "open play." Id. at 164.3 He presumed they were afraid of Mr. Galbreath. See id. Officer Parton's arrest report, however, did not reflect this observation. Rather, it merely suggested he observed "several adult women accompanied by approx[imately] 8 to 10 children," who "were playing on the playground equipment," roughly "20 yards from" Mr. Galbreath's location. Id. at 160. Nothing in the arrest report suggests Officer Parton spoke with any of these individuals to confirm whether they were in fact alarmed, and the 911 caller testified in her deposition [**5] that she had never met Officer Parton before. See id. at 157. And although Officer Parton asserted in his arrest report that he asked Mr. Galbreath if he had a "legit[i]mate purpose" for being in the park, id. at 160, Mr. Galbreath disputes this fact. Officer Parton arrested Mr. Galbreath for "disorderly conduct" under Oklahoma City Municipal Code § 30-81(b), which defines the offense as "caus[ing] public alarm without justification." Although the City initially charged Mr. Galbreath under the ordinance, it later dismissed 3 We draw this statement from Officer Parton's response to Mr. Galbreath's interrogatories during the discovery conducted in the district court. See Aplt. Appx., Vol. I at 161-68. 568 Fed. Appx. 534, *535; 2014 U.S. App. LEXIS 10824, **2 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 19 of 106 Page 6 of 11 the charge. B.Procedural History On October 12, 2011, Mr. Galbreath sued Officer Parton and Oklahoma City under 42 U.S.C. § 1983 in Oklahoma state court, alleging several violations of federal law.4 The defendants removed the case to the United States District Court for the Western District of Oklahoma. Mr. Galbreath filed an amended complaint in which he argued (1) Officer Parton arrested him without probable cause and (2) the City's disorderly conduct ordinance was unconstitutionally vague [**6] in violation of the Due Process Clause of the Fourteenth Amendment.5 The complaint sought damages, declaratory relief, and an injunction prohibiting the City from enforcing § 30-81. The City unsuccessfully moved to dismiss Mr. Galbreath's claims for injunctive relief. After discovery, Officer Parton moved for summary judgment on qualified immunity grounds and the City moved for summary judgment on Mr. Galbreath's municipal liability claims. Mr. Galbreath moved for declaratory judgment on his claims against the City. The [**7] court denied Mr. Galbreath's motion and granted summary judgment in favor of the defendants. It first determined that Mr. Galbreath lacked standing to seek prospective relief—either declaratory or injunctive—because he did not allege a credible threat of future prosecution under the ordinance. The court therefore denied Mr. Galbreath's motion for declaratory judgment on these claims and dismissed them with prejudice. 4 Mr. Galbreath also asserted a claim under the Oklahoma Governmental Tort Claims Act, but it is not relevant to this appeal. See Aplt. Appx., Vol. I at 76, 241, 369. 5 In his amended complaint, Mr. Galbreath also alleged (1) Officer Parton violated the First Amendment by arresting Mr. Galbreath for engaging in protected expression and (2) the City's ordinance violates the First Amendment because of its overbreadth. The district court determined Mr. Galbreath "confessed" the first claim by failing to rebut Officer Parton's motion on that issue and affirmatively abandoned the second in his response to the City's motion for summary judgment. See Aplt. Appx., Vol. I at 365-66. [*537] The district court next granted Officer Parton's request for qualified immunity, concluding he had probable cause to arrest Mr. Galbreath and any violation of Mr. Galbreath's rights was not otherwise clearly established. Finally, the court granted summary judgment in the City's favor on Mr. Galbreath's remaining void-for- vagueness claim for damages and retrospective declaratory relief. The court first concluded he could not bring a facial vagueness challenge because he was not seeking pre-enforcement review and failed to allege the ordinance threatened constitutionally protected activity. Left to address an as-applied due process vagueness claim, the district court determined Mr. Galbreath had sufficient notice that his behavior could have fallen within the ordinance's description [**8] of prohibited conduct. Accordingly, the district court dismissed Mr. Galbreath's case. Mr. Galbreath now appeals. II. DISCUSSION On appeal, Mr. Galbreath has abandoned most of his claims from the district court.6 In his opening brief, Mr. Galbreath contends the district court erred by (A) granting Officer Parton qualified immunity on his Fourth Amendment claim and (B) concluding that Oklahoma City's disorderly conduct statute was not void-for-vagueness in violation of the Due Process Clause of the Fourteenth Amendment. We address these arguments in turn after discussing our standard of review. HN2[] We review a district court's grant of summary judgment de novo, "using the same standard applied by the district court pursuant to 6 As noted above, see supra note 5, Mr. Galbreath withdrew his First Amendment overbreadth claim in the summary judgment briefing before the district court. See Aplt. Appx., Vol. I at 312. Additionally, the district court determined that Mr. Galbreath conceded his First Amendment free expression claim by failing to respond to Officer Parton's motion on that issue.See id. at 365 & n.22. Mr. Galbreath does not press either argument on appeal. Nor does he challenge the district court's rejection of his plea for prospective relief. See Oral Arg. Recording (6:14-6:20). We therefore do not consider any [**9] of these claims. 568 Fed. Appx. 534, *536; 2014 U.S. App. LEXIS 10824, **5 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 20 of 106 Page 7 of 11 Fed. R. Civ. P. 56(a)."Cillo v. City of Greenwood Village, 739 F.3d 451, 461 (10th Cir. 2013);see also Tabor v. Hilti, Inc., 703 F.3d 1206, 1215 (10th Cir. 2013). HN3[] We must "view facts in the light most favorable to" the non-moving party, Mr. Galbreath, "resolving all factual disputes and reasonable inferences" in his favor. Cillo, 739 F.3d at 461.HN4[] Summary judgment shall be granted if "there is no genuine dispute as to any material fact" and the moving party is "entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a); see also Cillo, 739 F.3d at 461.HN5[] "A fact is material if, under governing law, it could [affect] the outcome of the lawsuit." Cillo, 739 F.3d at 461 (quoting EEOC v. Horizon/CMS Healthcare Corp., 220 F.3d 1184, 1190 (10th Cir. 2000)).HN6[] A factual dispute is "genuine if a rational jury could find in favor of the nonmoving party on the evidence presented." Id. (quotations omitted). A.Qualified Immunity for Officer Parton on the Fourth Amendment Claim HN7[] At summary judgment, courts must grant qualified immunity unless the plaintiff [**10] meets a two-part burden to "show (1) a reasonable jury could find facts supporting a violation of a constitutional right, which (2) was clearly established at the time of the defendant's conduct." Estate of Booker [*538] v. Gomez, 745 F.3d 405, 411 (10th Cir. 2014); see also Saucier v. Katz, 533 U.S. 194, 202, 121 S. Ct. 2151, 150 L. Ed. 2d 272 (2001) (asking whether "a violation could be made out on a favorable view of the parties' submissions"), receded from on other grounds by Pearson v. Callahan, 555 U.S. 223, 129 S. Ct. 808, 172 L. Ed. 2d 565 (2009). Courts may "exercise their sound discretion in deciding which of the two" steps of the "qualified immunity analysis should be addressed first in light of the circumstances in the particular case at hand." Pearson, 555 U.S. at 236. Because Mr. Galbreath fails to meet the second step, we need not and do not reach the first. His opening brief makes no mention of clearly established law, and at oral argument, his counsel acknowledged that he cannot point to any clearly established federal law giving Officer Parton notice that the arrest was unconstitutional. See Oral Arg. Recording (10:10-11:05). Indeed, when asked whether he had "just conceded that the law wasn't clearly established," Mr. Galbreath's counsel responded, [**11] "Yes Your Honor." Id. (10:10- 10:23). Mr. Galbreath therefore fails to meet his burden to show that Officer Parton's actions violated clearly established law.7 We therefore proceed to Mr. Galbreath's void-for- vagueness claim against the City. B.Void-for-Vagueness Claim against the City Mr. Galbreath's remaining claim seeks to hold Oklahoma City liable because the disorderly conduct ordinance was void for vagueness as applied. In his amended complaint, Mr. Galbreath requested damages as well as a "declaration that Oklahoma City Ordinance 30-81 is unconstitutionally void for vagueness on its face and as applied by [Officer] Parton in violation of the Due Process Clause." Aplt. Appx., Vol. I at 37. At oral argument, however, Mr. Galbreath's counsel abandoned his challenge to the ordinance's facial validity. See Oral Arg. Recording (4:00-4:07, 6:07- 6:28). Our consideration of Mr. Galbreath's void-for- vagueness claim is therefore limited [**12] to (1) whether the City may be held liable under Monell v. Dep't of Soc. Servs. of City of New York, 436 U.S. 658, 98 S. Ct. 2018, 56 L. Ed. 2d 611 (1978), for an as-applied violation, and if so, (2) whether the district court erred in granting summary judgment to the City on the merits. See Collins v. City of Harker Heights, 503 U.S. 115, 120, 112 S. Ct. 1061, 117 L. Ed. 2d 261 (1992) (HN8[] resolving § 1983 claims against municipalities requires consideration of whether "the city is responsible" for harm "caused by a constitutional violation"). Mindful that Mr. Galbreath need only raise a genuine dispute of material fact to survive summary judgment, we answer both questions in 7 In reaching this conclusion, we express no opinion on whether Mr. Galbreath has satisfied the first step of the qualified immunity inquiry—that a reasonable jury could find Officer Parton lacked probable cause to arrest Mr. Galbreath for disorderly conduct. 568 Fed. Appx. 534, *537; 2014 U.S. App. LEXIS 10824, **9 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 21 of 106 Page 8 of 11 the affirmative.8 1.Municipal Liability The City argues "even if the ordinance was vague as applied to [Mr.] Galbreath's specific behavior, the City may not be held liable because [it] does not maintain a policy of applying the ordinance in an unconstitutional manner." Okla. City Aplee. Br. at 27. We disagree. Our precedent forecloses the City's argument. We have held that HN9[] an as-applied challenge to an ordinance can give rise to [*539] municipal liability. In Christensen v. Park City Mun. Corp., 554 F.3d 1271 (10th Cir. 2009), [**13] Park City police officers arrested the plaintiff for selling artwork on public property without a license in violation of two city ordinances. See id. at 1274. The plaintiff sued Park City for damages and declaratory relief, alleging the ordinances were unconstitutional as applied to his expressive activity in violation of the First Amendment.See id. The district court granted Park City's motion to dismiss, reasoning the city could not be held liable for a single unlawful application of an otherwise constitutional ordinance. See id. at 1274-75;see also Christensen v. Park City Mun. Corp., No. 2:06-CV-202 TS, 2007 U.S. Dist. LEXIS 74122, 2007 WL 2908288, at *1 (D. Utah Oct. 3, 2007) (HN10[] "[A] city will not automatically be liable under § 1983 if one of its employees happened to apply a constitutional policy in an unconstitutional manner . . . ." (quotations and alterations omitted)). We reversed, reasoning "[i]f it turns out that the relevant ordinances are unconstitutional, whether on their face or as applied to Mr. Christensen, the liability falls on the city." Christensen, 554 F.3d at 1279 (emphasis added). We concluded HN11[] municipal entities "may be subject to liability under § 1983" if they "make[] and enforce[] [**14] a law that is unconstitutional as applied." Id. 1280. Here, "there is no question" HN12[] Oklahoma City's disorderly conduct ordinance, like the "city ordinances" at issue in Christensen, "reflect[s] the 8 In doing so, we express no opinion on the ordinance's facial validity. 'official policy' of the municipality." Id. at 1279; see also Monell, 436 U.S. at 690 ("ordinance"); Connick v. Thompson, 131 S. Ct. 1350, 1359, 179 L. Ed. 2d 417 (2011) ("[o]fficial municipal policy" includes the "decisions of a government's lawmakers"). Officer Parton arrested Mr. Galbreath for violating the ordinance. See Aplt. Appx., Vol. I at 191 (police report asserting that Mr. Galbreath "was placed under arrest for disorderly conduct"), 197 (citation alleging Mr. Galbreath "commit[ed]" the "offense" of "Disorderly Conduct"). Consequently, if the ordinance was unconstitutional as applied to Mr. Galbreath's conduct, then Oklahoma City "may be subject to liability under § 1983."Christensen, 554 F.3d at 1280. 2.Vagueness As Applied We review the district court's summary judgment ruling on Mr. Galbreath's as-applied vagueness claim de novo. See United States v. Protex Industries, Inc., 874 F.2d 740, 743 (10th Cir. 1989) (HN13[] "The question of whether a statute has been rendered unconstitutionally vague as applied is a question [**15] involving issues of law."); see also Faustin v. City, Cnty. of Denver, Colo., 268 F.3d 942, 947 (10th Cir. 2001) (reviewing grant of summary judgment on vagueness claim de novo). HN14[] "To satisfy due process, 'a penal statute [must] define the criminal offense [1] with sufficient definiteness that ordinary people can understand what conduct is prohibited and [2] in a manner that does not encourage arbitrary and discriminatory enforcement.'" Skilling v. United States, 561 U.S. 358, 130 S. Ct. 2896, 2927-28, 177 L. Ed. 2d 619 (2010) (quoting Kolender v. Lawson, 461 U.S. 352, 357, 103 S. Ct. 1855, 75 L. Ed. 2d 903 (1983)). HN15[] For an as-applied vagueness challenge, we must tether our analysis to the factual context in which the ordinance was applied. See United States v. Franklin-El, 554 F.3d 903, 910 (10th Cir. 2009) ("Because this is an as-applied challenge, we consider this statute in light of the charged conduct."). At summary judgment, we view the evidence in the light most favorable to the non- moving party—here, Mr. Galbreath. See, e.g., Cillo v. City of Greenwood Village, 739 F.3d 451, 461 (10th Cir. 2013). 568 Fed. Appx. 534, *538; 2014 U.S. App. LEXIS 10824, **12 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 22 of 106 Page 9 of 11 [*540] The City's ordinance provides:HN16[] "A person [**16] is guilty of disorderly conduct, a Class 'a' offense, when such person: . . . causes public alarm without justification." City of Oklahoma City, Ordinance No. 22210, § 30-81(b) (adopted May 6, 2003). The ordinance does not define "public alarm" or "without justification," and the parties have not pointed us to an Oklahoma case construing these terms. "We are thus relegated, at best, to the words of the ordinance itself." Coates v. City of Cincinnati, 402 U.S. 611, 614, 91 S. Ct. 1686, 29 L. Ed. 2d 214 (1971);see also City of Chicago v. Morales, 527 U.S. 41, 68, 119 S. Ct. 1849, 144 L. Ed. 2d 67 (1999) (O'Connor, J., concurring) ("[W]e cannot impose a limiting instruction that a state supreme court has declined to adopt."). Mr. Galbreath contends this language was unconstitutionally vague as applied to his activity in the park because (1) it failed to give adequate notice to a person of ordinary intelligence that his conduct was unlawful and (2) ceded too much enforcement discretion to Officer Parton. Because we conclude the district court erred in granting summary judgment to the City on the adequate notice element, we do not consider whether the ordinance ceded too much enforcement discretion to Officer Parton. HN17[] In evaluating the adequate notice element, [**17] we must determine whether a reasonable person in Mr. Galbreath's position would have "'fair notice from the language' of the [ordinance] 'that the particular conduct which he engaged in was punishable.'" United States v. Baldwin, 745 F.3d 1027, 1031 (10th Cir. 2014) (quoting Parker v. Levy, 417 U.S. 733, 755, 94 S. Ct. 2547, 41 L. Ed. 2d 439 (1974));see also United States v. Harris, 705 F.3d 929, 932 (9th Cir. 2012) ("In an as-applied challenge, a statute is unconstitutionally vague if it fails to put a defendant on notice that his conduct was criminal. For statutes involving criminal sanctions the requirement for clarity is enhanced." (quotations and alterations omitted)). In granting the City's motion for summary judgment on Mr. Galbreath's as-applied vagueness claim, the district court reasoned briefly as follows: For no apparent reason, plaintiff was behaving in a public place in an alarming or disconcerting manner. When given the opportunity to explain, plaintiff replied "my morning exercises" and proceeded immediately with conduct which a reasonable person might have viewed as threatening, or at least as something other than an ordinary "morning exercise." While plaintiff's arrest, under the circumstances as we [**18] now know them to be, was perhaps unfortunate, it did not violate his due process rights. Galbreath v. City of Oklahoma City, No. CIV-11- 1336-HE, 2012 U.S. Dist. LEXIS 152652, 2012 WL 5289456, at *8 (W.D. Okla. Oct. 24, 2012). On its face, the district court's analysis points to denying summary judgment, not granting it. If a reasonable person "might" have viewed Mr. Galbreath's activity in the park as "threatening" or "something other than" ordinary morning exercises, then a reasonable person could also conclude Mr. Galbreath's conduct was neither threatening nor out of the ordinary. The district court's analysis turned well-established principles of summary judgment on their head. Mr. Galbreath testified he was singing and doing ballet exercises in high-heel shoes as a form of physical therapy to relieve pain from a hip disorder. He exercised with the assistance of a roughly 3- foot-long cane. He twirled his cane for a few seconds in a choreographed dance move when Officer Parton confronted him. At that time, Mr. Galbreath had been at the park about five minutes. Despite [*541] these facts, the district court concluded Mr. Galbreath "was behaving in a public place in an alarming or disconcerting manner." Galbreath, 2012 U.S. Dist. LEXIS 152652, 2012 WL 5289456, at *8. [**19] In doing so, "the court below credited the evidence of the party seeking summary judgment and failed properly to acknowledge key evidence offered by the party opposing that motion." Tolan v. Cotton, 134 S. Ct. 1861, 1867-68, 188 L. Ed. 2d 895 (2014). Viewing the facts in the light most favorable to Mr. Galbreath, a reasonable jury could conclude he lacked fair notice that his conduct in the park could 568 Fed. Appx. 534, *539; 2014 U.S. App. LEXIS 10824, **15 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 23 of 106 Page 10 of 11 lead to criminal sanctions under the City's disorderly conduct ordinance. First, nothing in the plain language of the ordinance suggests that singing and performing choreographed ballet moves in the park with a 3- foot cane while wearing high heels would cause "public alarm." See American Heritage Dictionary 39 (5th ed. 2011) (defining HN18[] "alarm" as "[s]udden fear or concern caused by the realization of danger or an impending setback"); see also Bell v. Keating, 697 F.3d 445, 462 (7th Cir. 2012) (holding that the term "alarm," as used in a municipal ordinance, was unconstitutionally vague in part because it failed to give individuals of common comprehension notice of the prohibited conduct). Second, the ordinance's plain language failed to give Mr. Galbreath notice that any public alarm caused by these morning [**20] exercises would be "without justification." See Black's Law Dictionary (9th ed. 2009) (defining HN19[] "justification" as "[a] lawful or sufficient reason for one's acts or omissions"); cf. Morales, 527 U.S. at 56-57 (plurality op.) (ordinance forbidding "remain[ing] in any one place with no apparent purpose" unconstitutionally vague in part because it failed to give adequate notice); Jim Crockett Promotion, Inc. v. City of Charlotte, 706 F.2d 486, 489 (4th Cir. 1983) (holding, without any "difficulty," "that the term 'unnecessary' in the general prohibitory language of the Ordinance [was] unconstitutionally vague"). Third, the ordinance lacks a scienter requirement, which could have mitigated the indefiniteness of the other terms when applied to Mr. Galbreath's conduct. See Hill v. Colorado, 530 U.S. 703, 732, 120 S. Ct. 2480, 147 L. Ed. 2d 597 (2000) (HN20[ ] fair notice concerns can be "ameliorated" by the fact that the challenged statute "contains a scienter requirement"); United States v. Gaudreau, 860 F.2d 357, 360 (10th Cir. 1988) ("[A] scienter requirement may mitigate a criminal law's vagueness by ensuring that it punishes only those who are aware their conduct is unlawful."); Stahl v. City of St. Louis, 687 F.3d 1038, 1041 (8th Cir. 2012) [**21] (holding that an ordinance was unconstitutionally vague in part because it lacked a scienter requirement in that violation turned on the reactions of third parties rather than the individual whose actions were involved). Given the foregoing, a reasonable jury could find the ordinance failed to give a reasonable person in Mr. Galbreath's position "fair notice . . . that the particular conduct which he engaged in was punishable." Baldwin, 745 F.3d at 1031 (quotations omitted). In concluding otherwise, the district court "failed to view the evidence at summary judgment in the light most favorable to [Mr. Galbreath] with respect to the central facts of this case," Tolan, 134 S. Ct. at 1866.Perhaps facts will emerge on remand establishing Mr. Galbreath had adequate notice his conduct was unlawful. We express no opinion on that matter or whether the ordinance ceded too much enforcement discretion to Officer Parton in this instance. See Yellowbear v. Lampert, 741 F.3d 48, 64 (10th [*542] Cir. 2014) ("For now, however, these subtler (and admittedly more difficult) questions remain for the parties and district court to consider on remand."). We merely hold that the district court erred in granting [**22] summary judgment to the City at this juncture because a reasonable jury could find Mr. Galbreath lacked fair notice that his conduct could be punished. III. CONCLUSION For the foregoing reasons, we (1) affirm the district court's summary judgment grant of qualified immunity to Officer Parton and (2) reverse its summary judgment grant to the City on Mr. Galbreath's as-applied void-for-vagueness claim. We remand for further proceedings consistent with this opinion.9 ENTERED FOR THE COURT Scott M. Matheson, Jr. Circuit Judge 9 We agree with the parties that the appendix documents containing medical information about the appellant and not pertinent to the merits of this appeal should remain under seal. See Eugene S. v. Horizon Blue Cross Blue Shield of New Jersey, 663 F.3d 1124, 1136 (10th Cir. 2011). 568 Fed. Appx. 534, *541; 2014 U.S. App. LEXIS 10824, **19 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 24 of 106 Page 11 of 11 End of Document 568 Fed. Appx. 534, *542; 2014 U.S. App. LEXIS 10824, **22 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 25 of 106 Neutral As of: October 8, 2021 1:57 AM Z Hill v. Unnamed Arapahoe County Det. Officers United States District Court for the District of Colorado March 15, 2012, Decided; March 15, 2012, Filed Civil Action No. 11-cv-00835-PAB-KMT Reporter 2012 U.S. Dist. LEXIS 35604 *; 2012 WL 899278 DARIUS HILL, Plaintiff, v. UNNAMED ARAPAHOE COUNTY DETENTION OFFICERS, Individually and Severally, ARAPAHOE COUNTY SHERIFF J. GRAYSON ROBINSON, ARAPAHOE COUNTY CAPTAIN VINCE SAUTER, and THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF ARAPAHOE, Defendants. Subsequent History: Costs and fees proceeding at, Request granted Hill v. Unnamed Arapahoe County Det. Officers, 2012 U.S. Dist. LEXIS 35600 (D. Colo., Mar. 16, 2012) Core Terms Sheriff, training, allegations, custom, municipal, jail officials, constitutional right, fails, qualified immunity, cell, deliberate indifference, motion to dismiss, deprivation, rights, municipal liability, deliberately, conspiracy, Detention, policies, pretrial, Unnamed, constitutional violation, plaintiff's claim, jail cell, implemented, indifferent, detainees, supervise, flooded, notice Counsel: [*1] For Darius Hill, Plaintiff: Douglas Leo Romero, Timothy D. Edstrom, Douglas L. Romero, LLC, Law Office of, Denver, CO. For J. Grayson Robinson, Arapahoe County Sheriff; Unnamed Arapahoe County Detention Officers, Individually and Severally, Vince Sauter, Arapahoe County Captain, Arapahoe County, Board of County Commissioners, (actually named as The Board of County Commissioners of the County of Arapahoe), Defendants: Edward M. Caswall, Arapahoe County Attorney's Office, Littleton, CO. Judges: PHILIP A. BRIMMER, United States District Judge. Opinion by: PHILIP A. BRIMMER Opinion ORDER This matter is before the Court on the Motion to Dismiss [Docket No. 6] filed by defendants the Board of County Commissioners for Arapahoe County ("Arapahoe County"), Arapahoe County Sheriff J. Grayson Robinson, and Arapahoe County Sheriff's Office Captain Vince Sauter. Defendants seek to dismiss plaintiff's Complaint [Docket No. 1] pursuant to Fed. R. Civ. P. 12(b)(1) and (6). Docket No. 6 at 1. I. BACKGROUND Plaintiff Darius Hill is a state prisoner currently incarcerated at the Buena Vista Correctional Complex. Docket No. 1 at 2. This case arises out of Mr. Hill's pretrial detainment at the Patrick J. Sullivan Detention Center in Centennial, [*2] Colorado. Id. at 3, ¶ 9. Mr. Hill alleges that on April 23, 2010, his jail cell flooded as rainfall seeped through the cell walls. Id. Mr. Hill claims that, despite lodging numerous complaints with jail officials, his cell remained flooded for a period of three days. Id. at ¶ 10. Mr. Hill states that, because of water accumulation in his cell, he slipped, fell, and sustained injuries to his back, neck, and head. Id. at ¶ 11. Mr. Hill filed the current action as a result of this incident. Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 26 of 106 Page 2 of 7 In his complaint, Mr. Hill brings three claims against defendants pursuant to 42 U.S.C. § 1983 and one pursuant to 42 U.S.C. § 1986. Mr. Hill's first claim alleges that Arapahoe County violated his Fifth and Fourteenth Amendment rights by implementing policies and customs which created unreasonable risks to the health and safety of pretrial detainees. Docket No. 1 at 4, ¶¶ 15-17. Mr. Hill's second claim asserts that all defendants violated his Fifth and Fourteenth Amendment rights because they were deliberately indifferent to serious risks to his health and safety arising out of the conditions of his confinement. Id. at 5-6, ¶¶ 21- 22. Mr. Hill's third claim asserts that Sheriff Robinson, Captain Sauter, [*3] and Arapahoe County failed to adequately train and supervise jail officials. Id. at 6-7, ¶¶ 27-29. He alleges that Arapahoe County as the primary "policy maker" implemented customs, practices, and policies which led to the violation of Mr. Hill's constitutional rights. Id. at 8-9, ¶ 34. Finally, Mr. Hill brings a claim against all defendants for a failure to prevent a conspiracy to violate his civil rights pursuant to 42 U.S.C. § 1986. Id. at 10, ¶¶ 39-40. Mr. Hill asserts that all defendants had knowledge of the unlawful and malicious treatment received by pretrial detainees but failed to instruct, supervise, control, and discipline their subordinates. Id. at 10, ¶ 41. Mr. Hill contends that Sheriff Robinson and Captain Sauter had the power to prevent or aid in preventing the commission of said wrongs, but their failure to remedy the situation was tacit approval or ratification of the jail officials' conduct. Id. at ¶ 42. In relief, Mr. Hill seeks an award of compensatory and punitive damages in the amount of no less than $500,000 and an award for attorney's fees and costs pursuant to 42 U.S.C. § 1988.Id. at 11. On May 13, 2011, defendants filed a motion to dismiss pursuant to Rule 12(b)(1) [*4] and (6) of the Federal Rules of Civil Procedure [Docket No. 6]. Defendants argue that: (1) Mr. Hill fails to state a cognizable claim against Arapahoe County because all of the alleged facts rely on a theory of respondeat superior, which cannot sustain liability against government entities, Docket No. 6 at 7; (2) Mr. Hill fails to identify a specific policy or custom implemented by Arapahoe County and followed by jail officials which led to plaintiff's injuries, id.; (3) Mr. Hill fails to state a claim against Sheriff Robinson and Captain Sauter in their individual or official capacities because plaintiff does not allege that defendants had personal knowledge of the flooded jail cell, id. at 10; and (4) Mr. Hill cannot establish that Sheriff Robinson and Captain Sauter had the requisite state of mind to violate Mr. Hill's constitutional rights. Id. at 8. Accordingly, defendants contend that Sheriff Robinson and Captain Sauter are entitled to qualified immunity on all of plaintiff's claims. Id. at 12. II. STANDARD OF REVIEW Defendants seek to dismiss plaintiff's claims pursuant to Fed. R. Civ. P. 12(b)(1) for a lack of subject matter jurisdiction or pursuant to Fed. R. Civ. P. 12(b)(6) [*5] for failure state a claim upon which relief can be granted. Where a party moves to dismiss for lack of subject matter jurisdiction under Fed. R. Civ. P. 12(b)(1), the attack can be either a factual attack or a facial attack on the allegations of the complaint. Paper, Allied-Indus., Chemical & Energy Workers Int'l Union v. Cont'l Carbon Co., 428 F.3d 1285, 1292 (10th Cir. 2005). Where there is a facial attack on the sufficiency of the complaint, the Court must look to its factual allegations and accept them as true. See id.; Groundhog v. Keeler, 442 F.2d 674, 677 (10th Cir. 1971). Rule 12(b)(6) provides that a defendant may move to dismiss a claim for "failure to state a claim upon which relief can be granted." Fed. R. Civ. P. 12(b)(6). The Court's inquiry is "whether the complaint contains 'enough facts to state a claim to relief that is plausible on its face.'" Ridge at Red Hawk, LLC v. Schneider, 493 F.3d 1174, 1177 (10th Cir. 2007) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007)). "To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim for relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937, 1949, 173 L. Ed. 2d 868 (2009). [*6] A pleading that offers "labels and 2012 U.S. Dist. LEXIS 35604, *2 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 27 of 106 Page 3 of 7 conclusions" or "a formulaic recitation of the elements of a cause of action will not do." Id. Nor does the complaint suffice if it tenders "naked assertion[s]" devoid of "further factual enhancement." Id. Furthermore, conclusory allegations are "not entitled the assumption of truth."Id. at 1950. The Tenth Circuit has interpreted "plausibility" to refer to the scope of the allegations in the complaint rather than to mean "likely to be true." Robbins v. Okla. ex rel. Okla. Dep't of Human Servs., 519 F.3d 1242, 1247 (10th Cir. 2008). Thus, "if [allegations] are so general that they encompass a wide swath of conduct, much of it innocent, then the plaintiffs have not nudged their claims across the line from conceivable to plausible." Id. Additionally, "the degree of specificity necessary to establish plausibility and fair notice, and therefore the need to include sufficient factual allegations, depends on context." Id. at 1248. Complaints in § 1983 cases against individual government actors pose a greater likelihood of failures in notice and plausibility because they typically include complex claims against multiple defendants. Id. at 1248-49. In § 1983 [*7] cases, defendants often include the government agency and a number of government actors sued in their individual capacities. Therefore, it is important in such circumstances that the complaint make clear exactly who is alleged to have done what to whom, to provide each individual with fair notice of the basis of the claims against him or her, as distinguished from collective allegations against the state. Id. III. ANALYSIS A. Qualified Immunity Sheriff Robinson and Captain Sauter assert that they are entitled to qualified immunity against plaintiff's claims. Docket No. 6 at 12. Defendants assert that Mr. Hill fails to allege sufficient facts to show that defendants either personally violated his constitutional rights or were deliberately indifferent to a serious risk to Mr. Hill's health or safety. Id. Generally, government officials sued under § 1983 in their individual capacities have qualified immunity when their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Buckley v. Fitzsimmons, 509 U.S. 259, 268, 113 S. Ct. 2606, 125 L. Ed. 2d 209 (1993).In resolving a motion to dismiss based on qualified immunity, a court must consider whether the facts [*8] as alleged make out a violation of a constitutional right and whether the right at issue was clearly established at the time of defendant's misconduct. Leverington v. City of Colo. Springs, 643 F.3d 719, 732 (10th Cir. 2011).In Pearson v. Callahan, 555 U.S. 223, 129 S. Ct. 808, 172 L. Ed. 2d 565 (2009), the Supreme Court held that "judges of the district courts and the courts of appeals are in the best position to determine the order of decisionmaking that will best facilitate the fair and efficient disposition of each case." Id. at 242. Therefore, courts have discretion to "decid[e] which of the two prongs of the qualified immunity analysis should be addressed first in light of the circumstances in the particular case at hand." Id. at 236. Accordingly, the Court will first determine whether Mr. Hill alleges sufficient facts to show that Sheriff Robinson and Captain Sauter violated his constitutional rights. Mr. Hill brings claims against Sheriff Robinson and Captain Sauter in their individual capacities for: (1) failure to maintain humane jail cell conditions; and (2) conspiracy to engage in unconstitutional conduct in violation of 42 U.S.C. § 1986. 1. Cell Conditions As a pretrial detainee, Mr. Hill was protected by [*9] the Due Process Clause of the Fourteenth Amendment; however, in determining whether his rights to be free from cruel and unusual punishment were violated, the Court applies the same analysis applied to § 1983 claims alleging Eighth Amendment violations. Ledbetter v. City of Topeka, 318 F.3d 1183, 1188 (10th Cir. 2003). Thus, to assert a cognizable claim under the 2012 U.S. Dist. LEXIS 35604, *6 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 28 of 106 Page 4 of 7 Eighth Amendment, Mr. Hill must allege that Sheriff Robinson and Captain Sauter were deliberately indifferent to a substantial risk of serious harm. See Farmer v. Brennan, 511 U.S. 825, 834, 114 S. Ct. 1970, 128 L. Ed. 2d 811 (1994).The test for a "deliberate indifference" claim under the Eighth Amendment has both "an objective and a subjective component." Sealock v. Colorado, 218 F.3d 1205, 1209 (10th Cir. 2000).The objective component of the test is met if the harm suffered is sufficiently serious to implicate the Cruel and Unusual Punishment Clause. Farmer, 511 U.S. at 834.The subjective component is met if a prison official knows of and disregards excessive risks to an inmate's health and safety. See Tafoya v. Salazar, 516 F.3d 912, 916 (10th Cir. 2008). Accordingly, Mr. Hill must demonstrate both that the injury he suffered was sufficiently serious and [*10] that Sheriff Robinson and Captain Sauter acted with deliberate indifference. See id. Mr. Hill's allegations fail to meet the objective component of this inquiry. Mr. Hill's asserted injury is not sufficiently serious given that only "extreme deprivations are [sufficient to assert] a conditions- of-confinement claim." Hudson v. McMillian, 503 U.S. 1, 9, 112 S. Ct. 995, 117 L. Ed. 2d 156 (1992). For an alleged injury to be sufficiently serious a "prison official's act or omission must result in the denial of the minimal civilized measure of life's necessities." Farmer, 511 U.S. at 834.The purpose of the sufficiently serious requirement is "to limit claims to significant, as opposed to trivial, suffering."Kikumura v. Osagie, 461 F.3d 1269, 1291 (10th Cir. 2006),overruled on other grounds by Robbins, 519 F.3d at 1246-47.The fact that Mr. Hill slipped, fell, and suffered injuries is not an extreme deprivation and did not deprive Mr. Hill of the minimal measures of life's necessities. See Cook v. Corr. Corp. of Am., No. 09-cv-02967-PAB- BNB, 2010 U.S. Dist. LEXIS 35272, 2010 WL 1027407, at *2 (D. Colo. Mar. 18, 2010) (dismissing conditions of confinement claim based on slip-and-fall injury). Moreover, Mr. Hill fails to allege facts that indicate Sheriff [*11] Robinson and Captain Sauter acted with deliberate indifference. To meet the subjective element of this inquiry, Mr. Hill must allege that Sheriff Robinson and Captain Sauter knew that Mr. Hill faced a substantial risk of serious harm and disregarded that risk by failing to take reasonable measures to abate the harm. Hunt v. Uphoff, 199 F.3d 1220, 1224 (10th Cir. 1999). That is, "the official[s] must both be aware of the facts from which the inference could be drawn that a substantial risk of serious harm exists, and [they] must also draw the inference." Craig v. Eberly, 164 F.3d 490, 495 (10th Cir. 1998). Mr. Hill does not allege that Sheriff Robinson or Captain Sauter knew that his cell was flooded at any time during the three days alleged in the complaint or that Sheriff Robinson and Captain Sauter had any knowledge of their subordinates' denial of his request to change cells. On the contrary, all of Mr. Hill's claims against Sheriff Robinson and Captain Sauter are based, not on direct actions, but on their failure to supervise or train jail officials, Docket No. 1 at 6-7, ¶¶ 27-32, or on their negligent oversight. Id. at ¶ 23 (defendants failed to provide "the applicable standard [*12] of care to the Plaintiff"). The facts, as averred, do not allege that Sheriff Robinson or Captain Sauter knew of Mr. Hill's jail cell condition or that they ordered jail officials to keep Mr. Hill in a flooded jail cell. As such, Mr. Hill fails to establish the subjective element of a deliberate indifference claim.See Hovater v. Robinson, 1 F.3d 1063, 1066 (10th Cir. 1993) (deliberate indifference is a higher degree of fault than even gross negligence, let alone ordinary negligence). Accordingly, Sheriff Robinson and Captain Sauter are entitled to qualified immunity on this claim, and Mr. Hill's Fourteenth Amendment Due Process claim based on pretrial detention conditions will be dismissed. 2.42 U.S.C. § 1986 For a plaintiff to assert a claim under 42 U.S.C. § 1986, he must first assert a valid 42 U.S.C. § 1985(3) claim. See King v. Dingle, 702 F. Supp. 2d 1049, 1078 (D. Minn. 2010).Section 1986 allows an action against a party who: (1) knows that a 42 U.S.C. § 1985(3) violation will occur; (2) has the power to prevent the violation; and (3) fails to do so.See 42 U.S.C. § 1986.In order to establish a § 2012 U.S. Dist. LEXIS 35604, *9 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 29 of 106 Page 5 of 7 1985(3) claim, a plaintiff must allege: (1) a conspiracy; (2) to deprive plaintiff [*13] of equal protection or equal privileges and immunities; (3) an act in furtherance of the conspiracy; and (4) an injury or deprivation resulting therefrom. Tilton v. Richardson, 6 F.3d 683, 686 (10th Cir. 1993). A valid § 1985(3) claim must also allege a conspiracy that is motivated by "some racial, or perhaps otherwise class-based, invidiously discriminatory animus." Id. In this case, Mr. Hill does not allege a conspiracy based on racial animus.1 Instead, Mr. Hill asserts that defendants failed to adequately train jail officials to refrain from "conspiring to violate the rights, privileges, and immunities guaranteed to Plaintiff by the Constitution." Docket No. 1 at 10, ¶ 40. As such, Mr. Hill fails to assert a claim under § 1985(3) and therefore cannot establish a claim under 42 U.S.C. § 1986. Accordingly, Sheriff Robinson and Captain Sauter are entitled to qualified immunity on this claim and the Court will dismiss Mr. Hill's 42 U.S.C. § 1986 claim. B. Monell Claim Under § 1983, a municipality may [*14] be held liable for adopting an official policy or custom causing a violation of constitutional rights, but local governments cannot be sued under a respondeat superior theory of liability. See Monell v. Dep't of Soc. Servs. of City of N.Y., 436 U.S. 658, 690-91, 98 S. Ct. 2018, 56 L. Ed. 2d 611 (1978);Cannon v. City and Cnty. of Denver, 998 F.2d 867, 877 (10th Cir. 1993) ("The touchstone of a § 1983 action against a governmental body is an allegation that official policy is responsible for deprivation of rights protected by the Constitution."). Defendants argue that the Court should dismiss Mr. Hill's Monell claim against Arapahoe County because his allegations are based on the theory of respondeat superior. Docket No. 6 at 7. Defendants state that plaintiff may only assert 1 The Court notes that, nowhere in the complaint, has Mr. Hill represented that he belongs to any minority group or that his treatment was based on his or another detainee's minority status. claims against Arapahoe County if such claims are based on acts or orders officially sanctioned by the County. Id. at 9. Defendants claim that Mr. Hill fails to allege a specific custom, policy, or practice implemented by Arapahoe County that led to the alleged violation of his constitutional rights. Id. at 12. Defendants contend that, because all of plaintiff's claims are based on conclusory allegations related to a single incident, they fail to [*15] state a claim against Arapahoe County. Id. at 10. The Court agrees. To establish municipal liability under § 1983, a plaintiff must show: (1) the existence of a municipal policy or custom; and (2) a direct causal link between the policy or custom and the injury alleged. Graves v. Thomas, 450 F.3d 1215, 1218 (10th Cir. 2006);accord Myers v. Okla. Cnty. Bd. of Cnty. Comm'rs, 151 F.3d 1313, 1318 (10th Cir. 1998) (a plaintiff must show "(1) a municipal employee committed a constitutional violation, and (2) a municipal policy or custom was the moving force behind the constitutional deprivation."). The official policy requirement permits courts to "distinguish acts of the municipality from acts of employees of the municipality, and thereby make clear that municipal liability is limited to action for which the municipality is actually responsible." Pembaur v. City of Cincinnati, 475 U.S. 469, 479, 106 S. Ct. 1292, 89 L. Ed. 2d 452 (1986) (emphasis in original). Mr. Hill can establish a municipal custom or policy through the following means: (1) an officially promulgated policy; (2) a custom or persistent practice; (3) deliberately indifferent training that results in the violation of a plaintiff's federal protected rights; [*16] (4) a single decision by an official with final decision-making authority; or (5) ratification by an official with final decision-making authority of subordinates' decisions. See Brammer- Hoelter v. Twin Peaks Charter Acad., 602 F.3d 1175, 1189 (10th Cir. 2010). In his complaint, Mr. Hill does not identify a specific policy promulgated, implemented, or ordered by Arapahoe County. See generally Docket No. 1. Accordingly, Mr. Hill's Monell claim centers almost entirely on what he alleges are Arapahoe County's 2012 U.S. Dist. LEXIS 35604, *12 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 30 of 106 Page 6 of 7 customs, usages, or persistent practices governing the conduct of its jail officers.2 See Docket No. 1 at 4, ¶17 ("The policies, customs and usages of [Arapahoe County] constituted deliberate indifference"). Despite Mr. Hill's recitation of multiple alleged customs, it is clear from the complaint that Mr. Hill seeks to impose municipal liability under § 1983 on the basis of a single incident — his slip and fall accident caused by an allegedly wet cell floor. However, "[p]roof of a single incident of unconstitutional activity is not sufficient to impose [municipal] liability" because a single event cannot establish a custom or a persistent practice. Butler v. City of Norman, 992 F.2d 1053, 1055 (10th Cir. 1993). [*17] If Mr. Hill seeks to impose municipal liability on the basis of this single incident, he must show the particular illegal course of action was taken pursuant to a decision made by a person with authority to make policy decisions on behalf of Arapahoe County. Moss v. Kopp, 559 F.3d 1155, 1169 (10th Cir. 2009). Mr. Hill fails to assert such an allegation in his complaint. Because Mr. Hill has failed to show that any action taken by Sheriff Robinson or Captain Sauter violated his constitutional rights, he cannot establish that these alleged policies or practices were promulgated by a municipal policy maker. See Martinez v. Beggs, 563 F.3d 1082, 1091 (10th Cir. 2009) ("A county or sheriff in his official capacity cannot be held 'liable for constitutional violations when there was no underlying constitutional violation by any of its officers.'") (citation omitted); Hinton v. City of Elwood, 997 F.2d 774, 782 (10th Cir. 1993) (municipality may not be held liable where [*18] there was no underlying constitutional violation by any of its officers). Even if Mr. Hill was able to establish that a policy maker promoted these policies, his allegations would still be insufficient to impose liability against Arapahoe County because Mr. Hill's asserted policies are conclusory in nature and do not meet the Tenth Circuit's plausibility standard. 2 To the extent Mr. Hill brings a claim against Sheriff Robinson and Captain Sauter in their official capacities, it is the same as bringing a suit against the county. See Martinez v. Beggs, 563 F.3d 1082, 1091 (10th Cir. 2009). See, e.g., Docket No. 1 at 8, ¶ 34 ("A policy of providing inadequate training . . . [a] policy of non- prosecution and a tacit authorization of failure to adequately supervise . . . [a] a policy, custom or usage of failure to discipline"). These allegations encompass a wide swath of conduct and fail to provide Arapahoe County with any specific notice as to how each policy relates to the conduct of the unnamed jail officials in this case. See Robbins, 519 F.3d at 1247 ("Thus, 'plausible' cannot mean 'likely to be true' . . . [r]ather, 'plausibility' in this context must refer to the scope of the allegations in a complaint"). As such, they are not entitled to the assumption of truth. See Iqbal, 129 S.Ct. at 1950 (conclusory allegations are "not entitled to the assumption of truth"). Consequently, Mr. Hill's Monell claims rest [*19] on his assertion that Arapahoe County failed to supervise or train jail officials. Mr. Hill claims that "Defendants were aware of the lack of training given to officers in the [Sheriff's Department]" and that Arapahoe County knew that any training "given to police officers and sheriff deputies and jail guards regarding civil rights of pretrial detainees . . . was reckless or grossly negligent." Docket No. 1 at 7-8, ¶¶ 31-33. Again, it appears that Mr. Hill's failure to train claim is based wholly on his slip- and-fall accident. However, the Supreme Court in City of Canton v. Harris, 489 U.S. 378, 109 S. Ct. 1197, 103 L. Ed. 2d 412 (1989), precluded a meager quantum of proof from establishing that a municipality's inadequate training constitutes deliberate indifference to the constitutional rights of its inhabitants. Id. at 390-91.There, the Court made clear that a particular employee's training has little bearing on a municipality's entire training program and, thus, required that a plaintiff produce evidence of a specific deficiency in a municipality's "training program" and demonstrate how that deficiency actually caused the injury at issue. City of Canton, 489 U.S. at 391. [*20] Mr. Hill fails to allege these specific facts. First, Mr. Hill fails to provide any specific allegations about a deficiency in Arapahoe County's training procedures and fails to show how that deficiency led to the alleged constitutional violation. Mr. Hill has presented no facts to support 2012 U.S. Dist. LEXIS 35604, *16 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 31 of 106 Page 7 of 7 a claim that jail officials working at the Patrick J. Sullivan Detention Center were not adequately trained, or that Sheriff Robinson and Captain Sauter were deliberately indifferent to the need for more or different training. Randall v. Board of Cnty. Comm'rs, 184 F. App'x 723, 727 (10th Cir. 2006). Second, Mr. Hill did not name or identify specific jail officials who committed these alleged acts; that omission seriously undermines his attempt to hold Arapahoe County liable for actions deliberately taken by them. See Lopez v. LeMaster, 172 F.3d 756, 760-61 (10th Cir. 1999).Additionally, Mr. Hill has alleged no evidence concerning deficiencies in training of the particular jail officials in this case, nor has he shown that the county had a uniform policy of providing its jail officials with insufficient training in areas closely related to keeping detainees in unsafe cells. Id. There are no allegations [*21] that his particular jailers had not received training or that their failure to receive training was the cause of his injuries. City of Canton, 489 U.S. at 391 ("adequately trained officers occasionally make mistakes; the fact that they do says little about the training program or the legal basis for holding the city liable."). Consequently, Mr. Hill not only fails to establish the existence of a municipal policy or custom, but he fails to show a direct causal link between the policy or custom and his alleged injury. Graves, 450 F.3d at 1218. Accordingly, Mr. Hill's municipality liability claim against Arapahoe County is dismissed for failure to state a claim upon which relief may be granted. C. Unnamed Defendants In light of the foregoing, the only claims left in this action are brought against "Unnamed Arapahoe County Detention Officers." Docket No. 1 at 1. There is no indication in the docket that plaintiff has served these individuals with any of the pleadings. "If a defendant is not served within 120 days after the complaint is filed, the court -- on motion or on it own after notice to the plaintiff -- must dismiss the action without prejudice against that defendant or order that [*22] service be made within a specified time. But if the plaintiff shows good cause for the failure, the court must extend the time for service for an appropriate period." Fed. R. Civ. P. 4(m). Given that Mr. Hill has been granted two extensions to serve the unnamed defendants, Docket No 17; Docket No. 20, the Court will dismiss his claims against the unnamed Arapahoe County Detention Officers without prejudice pursuant to Rule 4(m). IV. CONCLUSION Accordingly, it is ORDERED that Defendants Robinson, Sauter and Arapahoe Countys' [sic] Motion to Dismiss [Docket No. 6] is GRANTED. It is further ORDERED that all of plaintiff's claims against the Unnamed Arapahoe County Detention Officers, Arapahoe County Sheriff J. Grayson Robinson, Arapahoe County Captain Vince Sauter, and the Board of County Commissioners for Arapahoe County are DISMISSED. It is further ORDERED that Defendants Robinson, Sauter, and Arapahoe County's Motion for Summary Judgment [Docket No. 32] is DENIED as moot. DATED March 15, 2012. BY THE COURT: /s/ Philip A. Brimmer PHILIP A. BRIMMER United States District Judge End of Document 2012 U.S. Dist. LEXIS 35604, *20 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 32 of 106 Neutral As of: October 8, 2021 1:51 AM Z Mehdipour v. Denwalt-Hammond United States Court of Appeals for the Tenth Circuit May 14, 2019, Filed No. 18-6161 Reporter 773 Fed. Appx. 463 *; 2019 U.S. App. LEXIS 14267 ** FARAMARZ MEHDIPOUR, Plaintiff - Appellant, v. LISA DENWALT-HAMMOND; C. WESLEY LANE, II; DAVID PRATER, Defendants - Appellees. Notice: PLEASE REFER TO FEDERAL RULES OF APPELLATE PROCEDURE RULE 32.1 GOVERNING THE CITATION TO UNPUBLISHED OPINIONS. Subsequent History: Motion denied by Mehdipour v. Denwalt-Hammond, 2020 U.S. LEXIS 3182 (U.S., June 15, 2020) Prior History: [**1] (D.C. No. 5:18-CV-00268- SLP) (W.D. Okla.). Mehdipour v. Denwalt-Hammond, 2018 U.S. Dist. LEXIS 104128 (W.D. Okla., June 21, 2018) Core Terms district court, invalidity, notice of appeal, sentence Case Summary Overview HOLDINGS: [1]-The inmate did not file his Fed. R. Civ. P. 60(b) motion Until August 7, 2018, which was 47 days after entry of the June 21 judgment, and it did not toll the time to appeal the underlying judgment, and the appellate court lacked jurisdiction to review that judgment; [2]-The inmate's notice of appeal was timely and the appellate court had jurisdiction to review that order; [3]-Success on the merits of the inmate's 42 U.S.C.S. § 1983 claims that the defendants maliciously prosecuted him, falsified court documents, tampered with court records, treated him differently than other similarly situated defendants, failed to correct those violations, and deprived him of a preliminary hearing, which resulted in the state trial court proceeding without jurisdiction, would necessarily imply the invalidity of his conviction. Outcome Judgment affirmed. LexisNexis® Headnotes Civil Procedure > Appeals > Reviewability of Lower Court Decisions > Timing of Appeals HN1[] Reviewability of Lower Court Decisions, Timing of Appeals The timely filing of a notice of appeal in a civil case is a jurisdictional requirement. And a notice of appeal in a civil case must be filed within thirty days after the entry of the judgment, order or decree being appealed, 28 U.S.C.S. § 2107(a). Although a Fed. R. Civ. P. 60 motion can toll the running of the 30-day appeal period until the district court disposes of the motion, it does so only if filed no later than 28 days after the judgment is entered, Fed. R. App. P. 4(a)(4)(A)(vi). Civil Procedure > Appeals > Standards of Review > Abuse of Discretion Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 33 of 106 Page 2 of 4 Civil Procedure > Parties > Pro Se Litigants > Pleading Standards HN2[] Standards of Review, Abuse of Discretion The appellate court reviews the denial of a Fed. R. Civ. P. 60(b) motion for abuse of discretion. The appellate court affords a plaintiff's pro se filings a liberal construction, but it does not act as his advocate. Judges: Before BRISCOE, McKAY, and LUCERO, Circuit Judges. Opinion by: Monroe G. McKay Opinion [*464] ORDER AND JUDGMENT* Mr. Faramarz Mehdipour, an Oklahoma state prisoner proceeding pro se, appeals the district court's judgment dismissing without prejudice a civil rights action he filed under 42 U.S.C. § 1983, and the court's denial of his Fed. R. Civ. P. 60(b) motion. We lack jurisdiction to review the underlying judgment because Mr. Mehdipour's notice of appeal was untimely. We have jurisdiction under 28 U.S.C. § 1291 to review the denial of his Rule 60(b) motion, and we affirm that denial. I. Background In 1993, Mr. Mehdipour was convicted in Oklahoma state court of intimidating a witness. That conviction was overturned on direct appeal. In *After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2);10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 1996, he was convicted of attempting to intimidate a witness after conviction of two or more felonies and sentenced to sixty years' imprisonment. That conviction and sentenced were affirmed. See Mehdipour v. State, 1998 OK CR 23, 956 P.2d 911 (Okla. Crim. App. 1998).Mr. Mehdipour has been unsuccessful in his attempts to overturn his conviction in state post-conviction and federal habeas corpus proceedings. See Mehdipour v. Okla. Ct. of Civil Appeals, 62 F. App'x 203, 209-10 (10th Cir. 2003) (recounting litigation history and denying certificate of appealability from denial of second habeas petition). In 2018, Mr. Mehdipour filed a pro se § 1983 complaint [**2] against the defendants. Two of them, Ms. Lisa Denwalt-Hammond and Mr. C. Wesley Lane, II, were Oklahoma County assistant district attorneys involved in the prosecutions referred to above, and the third, Mr. David Prater, was the Oklahoma County district attorney at the time of those prosecutions. Mr. Mehdipour alleged that in the criminal proceedings against him, defendants violated his constitutional rights by maliciously prosecuting him, falsifying court documents, tampering with court records, treating him differently than other similarly situated defendants, and failing to correct those violations. He also alleged constitutional violations based on the lack of preliminary hearings at either trial, which allegedly deprived the state court of jurisdiction. He sought damages and declaratory relief. A magistrate judge screened Mr. Mehdipour's complaint pursuant to 28 U.S.C. § 1915A(a) [*465] and (b) and provided the district court with a report and recommendation (R&R). The magistrate judge recommended dismissing the claims against Mr. Lane with prejudice on the basis of absolute prosecutorial immunity, and dismissing the claims against the other two defendants, and any claims generally challenging the 1996 conviction, [**3] as barred by Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364, 129 L. Ed. 2d 383 (1994). In Heck, the Supreme Court held that a § 1983 suit for damages caused by an allegedly unconstitutional conviction or imprisonment or by other unlawful actions is not cognizable if "a 773 Fed. Appx. 463, *463; 2019 U.S. App. LEXIS 14267, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 34 of 106 Page 3 of 4 judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence," unless the plaintiff proves the conviction or sentence has been invalidated. Id. at 486-87.1 Mr. Mehdipour timely objected to the R&R arguing that Mr. Lane was not entitled to absolute prosecutorial immunity. He did not address the application of Heck other than a conclusory assertion that he was "not attempting to overcome his conviction in this action" but would instead be challenging his conviction "in a separate action soon to be filed in [the federal district court]." R. at 53. The district court declined to dismiss the claims against Mr. Lane based on prosecutorial immunity but concluded that Heck barred all claims against all three defendants. The district court noted that in Mehdipour v. Chapel, 12 F. App'x 810, 813-14 (10th Cir. 2001), this court had determined that Heck barred virtually identical § 1983 claims Mr. Mehdipour raised in that case. The district court also reasoned that Mr. Mehdipour's assertion that he intended to challenge his conviction and sentence [**4] in a separate action underscored imposing the Heck bar to his § 1983 claims. Consequently, the district court dismissed the action without prejudice on June 21, 2018 and entered a separate judgment the same day. On August 7, 2018,2 Mr. Mehdipour filed a Rule 60 motion in which he argued that Heck did not apply to his case because he was only challenging the process used to convict him, not the result. The district court construed the motion as seeking relief under Rule 60(b)(1) and (b)(6) and denied it. The court first determined that Mr. Mehdipour's attempt to distinguish Heck came too late given his failure to object to the magistrate judge's recommendation 1 In Wilkinson v. Dotson, 544 U.S. 74, 82, 125 S. Ct. 1242, 161 L. Ed. 2d 253 (2005), the Supreme Court made clear that Heck applies "no matter the relief sought (damages or equitable relief)." 3 2 Although Mr. Mehdipour's Rule 60(b) motion was not actually filed until August 9, 2018, he placed it in the prison's system for processing legal mail, postage prepaid, on August 7, 2018. Under the prison mailbox rule, the motion is deemed filed on August 7. However, the two-day differential is ultimately immaterial to the disposition of this appeal. that dismissal under Heck was warranted. In the alternative, the district court concluded that the attempt to distinguish Heck lacked merit because, as noted in its dismissal order, this court had "found virtually identical § 1983 claims previously raised by [Mr. Mehdipour] against one or more of the Defendants to be barred by Heck." R. at 76 (citing Mehdipour, 12 F. App'x at 813). Finally, the district court denied the Rule 60(b) motion to the extent Mr. Mehdipour otherwise attempted to advance new claims or make other arguments not raised in his objection to the R&R. II. Appellate Jurisdiction HN1[] "[T]he timely filing [**5] of a notice of appeal in a civil case is a jurisdictional [*466] requirement." Bowles v. Russell, 551 U.S. 205, 214, 127 S. Ct. 2360, 168 L. Ed. 2d 96 (2007). And a notice of appeal in a civil case must be filed "within thirty days after the entry of [the] judgment, order or decree" being appealed. 28 U.S.C. § 2107(a). Mr. Mehdipour filed a notice of appeal on September 14, 2018, naming both the district court's underlying judgment and the denial of his Rule 60(b) motion. That was more than thirty days after the district court's June 21, 2018 judgment. Although a Rule 60 motion can toll the running of the 30-day appeal period until the district court disposes of the motion, it does so only if "filed no later than 28 days after the judgment is entered." Fed. R. App. P. 4(a)(4)(A)(vi). Mr. Mehdipour did not file his Rule 60(b) motion until August 7, 2018, which was 47 days after entry of the June 21 judgment. Therefore, it did not toll the time to appeal the underlying judgment, and we lack jurisdiction to review that judgment. Mr. Mehdipour's notice of appeal was filed 29 days after the entry of the order denying his Rule 60(b) motion on August 16, 2018, so it was timely under § 2107(a). We therefore have jurisdiction to review that order, but "not the underlying decision itself." Servants of the Paraclete v. Does, 204 F.3d 1005, 1009 (10th Cir. 2000). III. Merits 773 Fed. Appx. 463, *465; 2019 U.S. App. LEXIS 14267, **3 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 35 of 106 Page 4 of 4 HN2[] We review the denial of a Rule 60(b) motion for abuse of discretion. Id. We afford [**6] Mr. Mehdipour's pro se filings a liberal construction, but we do not act as his advocate. Yang v. Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008). We need not decide whether the district court abused its discretion in denying Mr. Mehdipour's Rule 60(b) motion on the ground that he advanced arguments he had not raised in his objections to the magistrate judge's R&R. Instead, we agree with the district court that Mr. Mehdipour failed to distinguish Heck. On appeal, Mr. Mehdipour emphasizes that his claims are about "the process (due process), not the result." Aplt. Opening Br. at 2. And he insists that he did not seek to invalidate his conviction but instead sought damages based on defendants' deprivation of his constitutional rights to adequate process.3 This line of argument overlooks that Heck bars even those § 1983 claims that "necessarily imply the invalidity of [a] conviction." Heck, 512 U.S. at 487 (emphasis added). Actual invalidation is not required. Success on the merits of Mr. Mehdipour's § 1983 claims that the defendants maliciously prosecuted him, falsified court documents, tampered with court records, treated him differently than other similarly situated defendants, failed to correct those violations, and deprived him of a preliminary hearing, which resulted in the state [**7] trial court proceeding without jurisdiction, would necessarily imply the invalidity of his conviction. We therefore conclude that the district court did not abuse its discretion in denying Mr. Mehdipour's Rule 60(b) motion. CONCLUSION We affirm the district court's denial of Mr. Mehdipour's Rule 60(b) motion and otherwise dismiss this appeal for lack of jurisdiction. We deny Mr. Mehdipour's motion for a default judgment. 3 Mr. Mehdipour also argues that the district court erred in concluding that all three defendants were entitled to absolute prosecutorial immunity, but the court did no such thing. We therefore do not address this argument. Entered for the Court Monroe G. McKay Circuit Judge End of Document 773 Fed. Appx. 463, *466; 2019 U.S. App. LEXIS 14267, **5 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 36 of 106 Neutral As of: October 8, 2021 1:50 AM Z Roberts v. Generation Next, LLC United States Court of Appeals for the Tenth Circuit April 22, 2021, Filed No. 20-2068 Reporter 853 Fed. Appx. 235 *; 2021 U.S. App. LEXIS 11927 **; 2021 WL 1573896 GALE ROBERTS, individually and d/b/a "Gone Working" (Pro Se), Plaintiff - Appellant, v. GENERATION NEXT, LLC; ESTATE OF RICHARD COOK; KATHARINE COOK FISHMAN; PAUL MATTHEW CASTER; ANTIQUITY ENCOUNTER; JOHN MELANCON; EXPEDITION RESOURCES, LLC; EXPLORATION OPES, LLC; DONALD PATTERSON; GERALD KEMLER; HOWARD TALKS; WILLIAM FLOTO; JANE AND JOHN DOES, Defendants - Appellees. Notice: PLEASE REFER TO FEDERAL RULES OF APPELLATE PROCEDURE RULE 32.1 GOVERNING THE CITATION TO UNPUBLISHED OPINIONS. Prior History: [**1] (D.C. No. 1:18-CV-00975-WJ- LF). (D. N.M.). Core Terms Expedition, district court, Venture, gold, conspiracy, treasure, time-barred, conversion, parties, limited liability company, test result, quasi- contract, third-party, artifacts, discovery, targets, summary judgment, allegations, obligations, quotation, marks, limitations period, proceeds, team, preliminary injunction, conspiracy claim, exploration, limitations, excavation, negotiated Case Summary Overview HOLDINGS: [1]-Because appellant knew the essential facts underpinning conspiracy, conversion, and tort claims no later than February 2014 and did not file the lawsuit until October 2018, the district court correctly dismissed the claims as time-barred; [2]-The district court did not err by concluding appellant was not a third-party beneficiary of a Antiquity Recovery Agreement, as the agreement did not indicate that the parties intended to benefit him; [3]-The district court did not err by dismissing contract and quasi-contract claims based on a joint venture agreement against four individuals, as they were not parties to and were therefore not liable under the contract; [4]- Appeal of an order denying a motion for a preliminary injunction was moot given that the district court has entered a final judgment on the merits and the effective time period of the requested injunction had passed. Outcome Dismissal and summary judgment orders affirmed. LexisNexis® Headnotes Civil Procedure > Appeals > Appellate Briefs Civil Procedure > Parties > Pro Se Litigants > Pleading Standards HN1[] Appeals, Appellate Briefs An appellant's pro se status entitles him to a liberal reading of his pleadings. Appellate courts thus make some allowances for deficiencies, such as unfamiliarity with pleading requirements, failure to cite appropriate legal authority, and confusion of legal theories. But they cannot take on the responsibility of serving as the appellant's attorney Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 37 of 106 Page 2 of 13 in constructing arguments and searching the record. Civil Procedure > Appeals > Standards of Review > De Novo Review Civil Procedure > ... > Defenses, Demurrers & Objections > Motions to Dismiss > Failure to State Claim Civil Procedure > Appeals > Summary Judgment Review > Standards of Review HN2[] Standards of Review, De Novo Review Appellate courts review de novo both the dismissal of a complaint under Fed. R. Civ. P. 12(b)(6) for failure to state a claim and a grant of summary judgment, applying the same standards that applied in the district court. Civil Procedure > ... > Defenses, Demurrers & Objections > Motions to Dismiss > Failure to State Claim Civil Procedure > ... > Pleadings > Complaints > Re quirements for Complaint HN3[] Motions to Dismiss, Failure to State Claim To 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. In conducting its review, the appellate court disregards conclusory allegations, but accepts all well-pleaded facts as true, viewing them in the light most favorable to the plaintiffs, and drawing all reasonable inferences in their favor. The appellate court's duty is to determine whether the complaint sufficiently alleges facts supporting all the elements necessary to establish an entitlement to relief under the legal theory proposed. Under the plausibility standard, dismissal for failure to state a claim is proper only where it is obvious that the plaintiff cannot prevail on the facts he has alleged. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Appropriateness Civil Procedure > Judgments > Summary Judgment > Entitlement as Matter of Law Civil Procedure > Appeals > Summary Judgment Review > Standards of Review Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Genuine Disputes Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Legal Entitlement HN4[] Entitlement as Matter of Law, Appropriateness At the summary judgment stage, the appellate court views facts in the light most favorable to the non-moving party and draws all reasonable inferences in their favor. Summary judgment is only appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law. Contracts Law > Third Parties > Beneficiaries > Claims & Enforcement Contracts Law > ... > Beneficiaries > Types of Third Party Beneficiaries > Intended Beneficiaries HN5[] Beneficiaries, Claims & Enforcement Under New Mexico law, one who is not a party to a contract cannot maintain suit upon it. But a third party may be a beneficiary of a contract, and as a beneficiary may have an enforceable right against a party to a contract. Whether a party is a third- party beneficiary depends on if the parties to the contract intended to benefit the third party. Such intent must appear either from the contract itself or from some evidence that the person claiming to be 853 Fed. Appx. 235, *235; 2021 U.S. App. LEXIS 11927, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 38 of 106 Page 3 of 13 a third party beneficiary is an intended beneficiary. Business & Corporate Law > Limited Liability Companies > Management Duties & Liabilities Business & Corporate Law > Limited Liability Companies > Member Duties & Liabilities HN6[] Limited Liability Companies, Management Duties & Liabilities Under N.M. Stat. Ann. § 53-19-13, a member of a limited liability company may be personally liable for his own tortious acts, whether or not he was acting for the company, but not for its contractual obligations. Governments > Legislation > Statute of Limitations > Time Limitations Torts > ... > Statute of Limitations > Begins to Run > Continuing Violations HN7[] Statute of Limitations, Time Limitations Under the continuing wrong doctrine, where a tort involves a continuing or repeated injury, the cause of action accrues at, and limitations begin to run from, the date of the last injury. But the doctrine cannot be employed where the plaintiff's injury is definite and discoverable, and nothing prevented the plaintiff from coming forward to seek redress. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Appropriateness Civil Procedure > Judgments > Summary Judgment > Entitlement as Matter of Law HN8[] Entitlement as Matter of Law, Appropriateness An evidentiary hearing is not required when the plaintiff's claims can be decided as a matter of law and the parties' pleadings establish that the defendants are entitled to summary judgment. Civil Procedure > Appeals > Appellate Jurisdiction > Final Judgment Rule Civil Procedure > Remedies > Injunctions > Prelimin ary & Temporary Injunctions HN9[] Appellate Jurisdiction, Final Judgment Rule A preliminary injunction is by its nature a temporary measure intended to furnish provisional protection while awaiting a final judgment on the merits and that entry of final judgment mooted appeal of preliminary injunction. Civil Procedure > Judicial Officers > Judges > Discretionary Powers Civil Procedure > Appeals > Frivolous Appeals HN10[] Judges, Discretionary Powers The decision whether to impose sanctions for a frivolous appeal is discretionary. Counsel: GALE ROBERTS, individually and d/b/a "Gone Working" (Pro se), DBA "Gone Working", Plaintiff - Appellant, Pro se, Pinedale, WY. For GENERATION NEXT, LLC, ESTATE OF RICHARD COOK, KATHARINE COOK FISHMAN, Defendants - Appellees: Travis G. Jackson, Meghan D. Stanford, Jackson Loman Stanford & Downey, Albuquerque, NM. JOHN MELANCON, Defendant - Appellee, Pro se, Mt. Enterprise, TX. For EXPEDITION RESOURCES, LLC, HOWARD TALKS, Defendants - Appellees: Carter Speer McDonnell, Lance Elton Shurtleff, Gordon Rees Scully Mansukhani, Denver, CO; Jared Daniel Albert Najjar, Hall & Evans, Santa Fe, NM. DONALD PATTERSON, Defendant - Appellee, Pro se, Sanford, FL. 853 Fed. Appx. 235, *235; 2021 U.S. App. LEXIS 11927, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 39 of 106 Page 4 of 13 For EXPLORATION OPES LLC, Defendant - Appellee: Lance Elton Shurtleff, Gordon Rees Scully Mansukhani, Denver, CO. Judges: Before MORITZ, BALDOCK, and EID, Circuit Judges. Opinion by: Bobby R. Baldock Opinion [*235] ORDER AND JUDGMENT* This appeal involves a dispute about a hunt for buried treasure. Appellant Gale Roberts, individually and for his company, Gone Working ("GW"), filed the underlying lawsuit claiming he agreed with the above-named defendants and others to fund a treasure exploration mission on Black Mesa, a hill area in New Mexico. [**2] He claimed the defendants conspired to find the buried treasure without his knowledge, relocate the cache offsite, and launder the proceeds, thus depriving him of his share. The district court dismissed some claims against some defendants pursuant to Fed. R. Civ. P. 12(b)(6) and dismissed the remaining claims on summary judgment. Roberts appeals only portions of the dismissal and summary judgment orders.1 [*236] Exercising jurisdiction *After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2);10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. 1 Roberts has abandoned any arguments he might have made regarding aspects of the dismissal and summary judgment orders he did not expressly challenge on appeal. See Conroy v. Vilsack, 707 F.3d 1163, 1170 (10th Cir. 2013). Accordingly, we consider only the issues raised in the opening brief. See Tran v. Trs. of State Colls. in Colo., 355 F.3d 1263, 1266 (10th Cir. 2004) ("Issues not raised in the opening brief are deemed abandoned or waived." (internal quotation marks omitted)). We deny Roberts' request for leave to re-file a brief of up to forty- five pages. See Aplt. Opening Br. at 25, 28. under 28 U.S.C. § 1291, we affirm. Factual Background Richard Cook's company, Generation Next, LLC ("Gen Next"), owned property on Black Mesa. Cook's daughter, Katherine Fishman, was legal counsel for Gen Next, and Paul Caster, another family member, was its general manager. Cook died in 2016. Fishman is the personal representative of his estate. When discussing Cook, Fishman, Caster, and Cook's estate as a group, we refer to then collectively as "the Cook Defendants." Cook hired John Melancon, an archeologist, to help lay claim to the gold and artifacts expected to be found on Black Mesa. Melancon was one of four managing members of Expedition Resources, LLC. In 2010, Expedition Resources and Gen Next entered into a one-year exclusive recovery agreement giving Expedition Resources the right [**3] to access the property for exploration. The other managing members of Expedition Resources were Donald Patterson, Gerald Kemler, and Howard Talks. Talks was a financier of gold- finding expeditions, and Patterson and Kemler were both treasure hunters. When discussing Expedition Resources, Melancon, Patterson, Kemler, and Talks as a group, we refer to them collectively as "the Expedition Resources Defendants."2 Expedition Resources ultimately lacked the necessary funding and the agreement expired without Expedition Resources ever having entered the property. According to the First Amended Complaint ("FAC") Roberts and Expedition Resources entered into a Joint Venture Agreement in November 2012 under 2 The original complaint named Exploration OPES, LLC, another entity related to some or all of the Expedition Resources Defendants, as a defendant, and although the First Amended Complaint listed Exploration OPES in the caption, it did not assert any claims against Exploration OPES, and Roberts does not raise any claims on appeal involving Exploration OPES. Accordingly, we do not discuss its alleged involvement in the events giving rise to Roberts' claims either in this background section or our analysis of the issues on appeal. 853 Fed. Appx. 235, *235; 2021 U.S. App. LEXIS 11927, **1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 40 of 106 Page 5 of 13 which Roberts agreed to finance and participate in an expedition to search for and recover gold and artifacts from Black Mesa in exchange for half of the discovered cache. Patterson negotiated the agreement on behalf of Expedition Resources and he and Roberts were the two signatories. The agreement provided that Roberts would be compensated only if gold and artifacts were found, and that any capital he contributed was "risk capital," meaning he would be reimbursed out of the proceeds, and Expedition [**4] Resources would have no liability for capital costs if the venture was unsuccessful. Aplt. App., Vol. II at 185. The FAC alleged that Melancon brokered the agreement with the approval of Cook, who owned the treasure maps that were to be used in the expedition, and that Cook "agreed to honor another one-year exclusive recovery agreement for a 50/50 split."Id. Vol. I at 25. In February 2013, several months after Expedition Resources and Roberts entered into the Joint Venture Agreement, Gen Next entered into an exclusive one-year land access and recovery agreement with Melancon's company, Antiquity Encounter, to search for and recover gold and artifacts from Black Mesa ("the Antiquity Recovery Agreement"). The FAC alleged that Melancon secured this agreement with Gen Next "on behalf of and in accordance with the Joint Venture Agreement . . . Roberts had with Expedition." Id. at 21. [*237] In March 2013, two gold targets were located using equipment Roberts had purchased for the expedition. As the targets were located, tension grew between Roberts, Patterson, and Kemler, the three treasure hunters on the expedition. According to the FAC, unbeknownst to Roberts, Patterson and Kemler located two additional gold targets on March 6 with the help of [**5] William Floto, another treasure hunter. Roberts alleged that Patterson, Kemler, and Floto dug up the gold in one of those targets and moved it offsite, then Kemler hid the March 6 test results and he and the others manufactured false results to deceive Roberts about the two targets they had discovered. Roberts began his excavation on March 16, 2013. "[S]everal days into the excavation," he discovered that Kemler had tried to hide the March 6 test results.Id. at 30. Later that month, Patterson and Kemler began transporting the gold and artifacts to Florida, where Floto lived. Roberts informed the Cook Defendants by e-m ail about the false test results Patterson, Kemler, and Floto had given him. When the Cook Defendants did not respond, Roberts concluded they were part of the conspiracy to avoid giving Roberts a share of the treasure Patterson, Kemler, and Floto had taken from the property. In September 2013, Cook and Roberts entered into a verbal agreement allowing Roberts to finish the excavation of the gold in the Black Mesa vaults. But the relationship between Roberts and other members of the team continued to deteriorate, and Caster and Fishman refused to allow him on the Black Mesa property. [**6] The Cook Defendants ultimately obtained a state court restraining order limiting Roberts' communication with them based on their claims that he had been acting irrationally and ambushed the then 87-year old Cook at his home in an attempt to gain entry to Black Mesa. In February 2014, the Cook Defendants sent Roberts an email indicating that their relationship with him had ended, that no treasure had been found on Black Mesa, and that they had "no intention of any further exploration on Black Mesa." Id. at 22. Contrary to that representation, however, Roberts alleged that soon after sending the email, Gen Next, Fishman, and Caster began removing gold and artifacts from one of the vaults. Also in February 2014, Melancon and Patterson negotiated a "secret" verbal agreement with Cook and Caster to use satellite technology obtained from a non-party to further evaluate Black Mesa. Id. at 21. Fishman "cancelled" the agreement, however, because the Antiquity Recovery Agreement had not yet expired. Id. at 39. Angry that Fishman had cancelled the agreement, Patterson told Roberts he was no longer wanted on the expedition and confirmed that Cook, Fishman, Caster, Melancon, Patterson, Kemler, and Talks had all "joined in [**7] a global conspiracy to get rid of . . . Roberts" and deprive him of his share of the treasure. Id. Patterson also 853 Fed. Appx. 235, *236; 2021 U.S. App. LEXIS 11927, **3 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 41 of 106 Page 6 of 13 "unknowingly confessed" to digging up and removing gold from Black Mesa in March 2013. Id. at 40. Procedural Background In February 2018, Roberts filed a lawsuit in the District Court for the District of Wyoming. The court concluded it lacked personal jurisdiction over the defendants and subject-matter jurisdiction over the claims, and it dismissed the complaint. In October 2018, Roberts filed this nearly identical lawsuit in the District Court for the District of New Mexico, asserting claims for breach of contract, breach of the implied covenant (quasi-contract), conspiracy, conversion, tort (fraudulent inducement, [*238] intentional misrepresentation, and tortious interference with contract), and equitable relief (promissory estoppel and quantum meruit/unjust enrichment) against the defendants individually and in various groupings.3 The contract and quasi-contract claims were based on both the Joint Venture Agreement between Roberts and Expedition Resources, and the Antiquity Recovery Agreement between Gen Next and Antiquity Encounter. Those claims were asserted against all defendants, regardless [**8] of whether they were parties to the contracts, and alleged that Roberts was entitled to recover under the Antiquity Recovery Agreement as a third-party beneficiary. The defendants moved to dismiss all of the claims against them under Fed. R. 12(b)(6) as either time- barred or for failure to state a claim. As pertinent here, the district court: • dismissed the conspiracy claim against all defendants both as time-barred and because civil conspiracy is not actionable as a separate claim; • dismissed all claims based in tort against all defendants as time-barred; • dismissed the contract and quasi-contract 3 The district court had diversity jurisdiction under 28 U.S.C. § 1332(a)(1) ("[D]istrict courts shall have original jurisdiction of all civil actions where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between . . . citizens of different States."). claims based on the Antiquity Recovery Agreement against all defendants because Roberts was neither a party nor a third-party beneficiary to that agreement; • dismissed the contract and quasi-contract claims against the Cook Defendants based on the Joint Venture Agreement because they were not parties to that agreement;4 • dismissed the contract and quasi-contract claims based on the Joint Venture Agreement against Melancon, Talks, Kemler, Floto, and Antiquity Encounter because they were not involved in the contract negotiations and were not parties to the agreement, and Melancon's, Talks', [**9] and Kemler's roles as managing members in Expedition Resources did not subject them to liability for its contractual obligations; and • dismissed the equitable claims against all defendants other than Patterson and Expedition Resources both as time-barred and because the dismissed defendants were not parties to contracts with Roberts and the FAC did not specify what promises and expectations those defendants breached. The only claims that survived the motions to dismiss were the breach of contract, breach of the implied covenant, promissory estoppel, and quantum meruit/unjust enrichment claims against Expedition Resources and Patterson, who negotiated and signed the Joint Venture Agreement as a managing member of Expedition Resources. The district court later granted defendants' motions for summary judgment on those claims, concluding (1) Roberts was not entitled to relief under the Joint Venture Agreement because it expressly provided he would be reimbursed and compensated only if [*239] the expedition was successful, and he presented no 4 The FAC also asserted claims against the Cook Defendants for breach of contract based on the September 2013 verbal agreement between Cook and Roberts, and breach of an implied-in-fact contract based on Roberts' agreement to sign a no-contact order in exchange for Fishman's and Caster's promises to facilitate a face-to-face meeting between Roberts and Cook. Roberts does not challenge the adverse rulings involving these claims, so we do not address them. 853 Fed. Appx. 235, *237; 2021 U.S. App. LEXIS 11927, **7 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 42 of 106 Page 7 of 13 evidence supporting his assertion that treasure was discovered on Black Mesa; (2) the implied covenant could not be used to override the express terms of [**10] the Joint Venture Agreement; and (3) equitable relief was not available for conduct governed by contract. Discussion 1. Standard of Review HN1[] As an initial matter, we recognize that Roberts' pro se status entitles him to a liberal reading of his pleadings. Ledbetter v. City of Topeka, 318 F.3d 1183, 1187 (10th Cir. 2003).We thus make some allowances for deficiencies, such as unfamiliarity with pleading requirements, failure to cite appropriate legal authority, and confusion of legal theories. See Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840 (10th Cir. 2005). But we "cannot take on the responsibility of serving as [his] attorney in constructing arguments and searching the record." Id.;see also Whitney v. New Mexico, 113 F.3d 1170, 1175 (10th Cir. 1997) (explaining that we "will not supply additional factual allegations to round out [a pro se litigant's] complaint or construct a legal theory on [his] behalf"). HN2[] We review de novo both the dismissal of a complaint under Rule 12(b)(6) for failure to state a claim and the grant of summary judgment, applying the same standards that applied in the district court.Brooks v. Mentor Worldwide LLC, 985 F.3d 1272, 1278 (10th Cir. 2021) (Rule 12(b)(6) dismissal); Rocky Mountain Prestress, LLC v. Liberty Mut. Fire Ins. Co., 960 F.3d 1255, 1259 (10th Cir. 2020) (summary judgment). HN3[] "To 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, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009) (internal quotation marks omitted). In conducting our review, we disregard conclusory [**11] allegations, but accept all well- pleaded facts as true, view them in the light most favorable to Plaintiffs, and draw all reasonable inferences in their favor. Brooks, 985 F.3d at 1281. Our duty is to "determine whether the complaint sufficiently alleges facts supporting all the elements necessary to establish an entitlement to relief under the legal theory proposed." Forest Guardians v. Forsgren, 478 F.3d 1149, 1160 (10th Cir. 2007). Under the plausibility standard, dismissal for failure to state a claim is "proper only where it is obvious that the plaintiff cannot prevail on the facts he has alleged." Kay v. Bemis, 500 F.3d 1214, 1217 (10th Cir. 2007) (internal quotation marks omitted). HN4[] At the summary judgment stage, we "view facts in the light most favorable to the non-moving party and draw all reasonable inferences in [their] favor."Dewitt v. Sw. Bell Tel. Co., 845 F.3d 1299, 1306 (10th Cir. 2017) (ellipsis and internal quotation marks omitted). "Summary judgment is only appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law." Foster v. Mountain Coal Co., 830 F.3d 1178, 1186 (10th Cir. 2016) (internal quotation marks omitted). 2. Rejection of Third-Party Beneficiary Theory Roberts first contends the district court erred by concluding he was not a third-party beneficiary of the Antiquity Recovery Agreement.5 We disagree. [*240] HN5[] Under New Mexico law, "one who is not a party to a contract [**12] cannot maintain suit upon it." Fleet Mortg. Corp. v. Schuster, 1991- NMSC 046, 112 N.M. 48, 811 P.2d 81, 82 (N.M. 1991). But "[a] third party may be a beneficiary of [a] contract, and as a beneficiary may have an enforceable right against a party to a contract." Id. "Whether a party is a third-party beneficiary depends on if the parties to the contract intended to benefit the third party." Id. at 82-83. "Such intent 5 Roberts framed this argument as a due process argument, but he did not provide any legal support for the assertion that the district court's adverse ruling on the third-party beneficiary issue violated his constitutional right to due process. Accordingly, we disregard that aspect of the argument. 853 Fed. Appx. 235, *239; 2021 U.S. App. LEXIS 11927, **9 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 43 of 106 Page 8 of 13 must appear either from the contract itself or from some evidence that the person claiming to be a third party beneficiary is an intended beneficiary." Valdez v. Cillessen & Son, Inc., 1987- NMSC 015, 105 N.M. 575, 734 P.2d 1258, 1264 (N.M. 1987). The signatories to the Antiquity Recovery Agreement were Cook and Fishman as managers of Gen Next, and Melancon for Antiquity Encounter. The agreement gave Melancon and Antiquity Encounter "the exclusive right to access and perform a non-destructive geophysical survey(s) on Black Mesa" from February 2013 through February 2014, and provided for a fifty-fifty split between Gen Next and Antiquity Encounter of any "valuables and artifacts."6 Aplt. App., Vol. I at 70-71. The agreement identified Roberts as one of Melancon's team members, and required Gen Next to protect the confidentiality of Roberts' "proprietary geophysical technology." Id. at 72. But the agreement did not address how Melancon would compensate his team, much less suggest Roberts or any other [**13] team member would share in the fifty-fifty split between Gen Next and Antiquity Resources. We agree with the district court's conclusion that the contract does not indicate that the parties intended to benefit Roberts.7 Contrary to his assertion, neither the fact that Fishman and Caster knew about the Joint Venture Agreement when they signed the Antiquity Resources Agreement, nor Melancon's alleged promise "that [Roberts'] 6 In evaluating whether Roberts' factual allegations meet the plausibility standard, we consider both his complaint and the documents attached as exhibits to the complaint, including the Antiquity Recovery Agreement. See Oxendine v. Kaplan, 241 F.3d 1272, 1275 (10th Cir. 2001);see also Fed. R. Civ. P. 10(c) ("A copy of a written instrument that is an exhibit to a pleading is a part of the pleading for all purposes."). 7 The district court held that "[a]t most" the provision identifying Roberts as a member of Melancon's team made him "an incidental beneficiary"—someone who has no contractual rights under the contract but who "'will derive a benefit from its performance.'" Aplt. App., Vol. I at 339 (quoting Fleet Mortg, 811 P.2d at 83 (holding incidental beneficiary "had no right to recover" under contract)). The issue before us is whether Roberts was a third-party beneficiary, not whether he was an incidental beneficiary, so we need not address that issue. interests, as the financier [of the expedition under the Joint Venture Agreement] would be protected," Aplt. Opening Br. at 8, establishes that Roberts was a third-party beneficiary of the Antiquity Resources Agreement. Cook's and Fishman's awareness of the Joint Venture Agreement and of Roberts' role as financier of the expedition is simply not a basis for concluding they intended to make him a beneficiary of the Antiquity Recovery Agreement. And while the two agreements were interrelated—the Joint Venture Agreement governed the conduct of the Black Mesa expedition and the Antiquity Recovery Agreement gave the team access to the property and governed what they could do there—the fact that both agreements were necessary for the expedition to happen does [**14] not make the parties to one agreement third-party beneficiaries of the [*241] other. Moreover, any promise Melancon made to protect Roberts' interests could not make Roberts a third-party beneficiary of the Antiquity Recovery Agreement without the agreement of the other parties to that contract. Such a promise might have affected how the proceeds of any discovered cache would have been divided between Roberts and Expedition Resources under the Joint Venture Agreement, but it would not have affected the division of proceeds between Gen Next and Antiquity Resources under the Antiquity Recovery Agreement. 3. Dismissal of Contract and Quasi-Contract Claims Against Melancon, Talks, Kemler, and Floto Roberts next contends the district court erred by dismissing the contract and quasi-contract claims based on the Joint Venture Agreement against Melancon, Talks, Kemler, and Floto. Again, we disagree. Expedition Resources is a limited liability company. Under New Mexico law: the debts, obligations and liabilities of a limited liability company, whether arising in contract, tort or otherwise, shall be solely the debts, obligations and liabilities of the . . . company. No member or manager of a limited 853 Fed. Appx. 235, *240; 2021 U.S. App. LEXIS 11927, **12 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 44 of 106 Page 9 of 13 liability [**15] company . . . shall be obligated personally for any debt, obligation or liability of the . . . company solely by reason of being a member or manager of the . . . company . . . . A person may be liable for any act or omission performed in his capacity as a manager of a limited liability company if there is a basis for liability. Nothing in this section shall be construed to immunize any person from liability for the consequences of his own acts or omissions for which he otherwise may be liable. N.M. Stat. Ann. § 53-19-13.HN6[] Under this statute, a member of a limited liability company may be personally liable for his own tortious acts, whether or not he was acting for the company, but not for its contractual obligations. The allegations in the FAC establish that the Joint Venture Agreement was between Expedition Resources and Roberts. Melancon, Talks, Kemler, and Floto were not parties to and were therefore not liable under the contract, and Melancon, Talks, and Kemler cannot be held personally liable for Expedition Resources' obligations under the contract.See id. Accordingly, the district court correctly dismissed the contract and quasi-contract claims against these defendants. See id.§ 53-19- 14 (providing that subject [**16] to an exception not applicable here, "[a] member of a limited liability company is not a proper party to a proceeding against the limited liability company solely by reason of being a member of the limited liability company"); see also Kreischer v. Armijo, 1994-NMCA-118, 118 N.M. 671, 884 P.2d 827, 829 (N.M. Ct. App. 1994) (explaining that agents of a corporate entity cannot be held personally liable for its contractual obligations and affirming dismissal of claim against corporate agent based on the company's contract). 4. Dismissal of Conspiracy, Conversion, and Tort Claims as Time-Barred We also reject Roberts' contention that the district court erred by dismissing the conspiracy, conversion, and tort claims as time-barred. The basis for these claims was as follows: •Conspiracy: The FAC alleged the conspiracy claim against all defendants individually and in various groupings, and although the specific conduct underpinning the claim varied from defendant to defendant, it was based on the same basic theory as to all of [*242] them—that they schemed to prevent Roberts from discovering hidden reserves of gold in order to deprive him of his share of the treasure. Based on the factual allegations in the FAC, the court determined that the claim was based on events that occurred before [**17] September 2013. •Conversion: The conversion claim was asserted against all defendants and was based on the alleged discovery of treasure on Black Mesa, its removal from the property, and the laundering and division of the proceeds among the defendants, all without Roberts' knowledge. •Fraudulent Inducement: The claim against the Expedition Resources Defendants alleged that they made false representations to Roberts in November 2012 when they solicited his participation in an expedition on Black Mesa. The claim against the Cook Defendants alleged that they manipulated Roberts into signing the temporary restraining order in October 2013 by telling him they would facilitate a face-to-face meeting between him and Cook. Floto and Antiquity Resources were not named in the fraudulent inducement claim. •Intentional Misrepresentation: The intentional misrepresentation claim against Patterson and Kemler alleged that they gave Roberts misleading test results and other data to hide their discovery of additional gold targets in March 2013. The claim against the Cook Defendants was based on the February 2014 email telling Roberts that the expedition had found no treasure and that they did not intend [**18] to conduct further exploration on Black Mesa. The other defendants were not named in this claim. 853 Fed. Appx. 235, *241; 2021 U.S. App. LEXIS 11927, **14 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 45 of 106 Page 10 of 13 •Tortious Interference with Contract: This claim was asserted only against Floto, Fishman, and Caster. It alleged that Floto located and removed treasure from Black Mesa in March 2013 "without giving any of the existing agreements and contracts any consideration," Aplt. App., Vol. I at 51, and that in September 2013, Fishman and Caster interfered with the verbal agreement between Roberts and Cook. The district court concluded, and Roberts does not dispute, that the applicable limitations periods were four years for the conversion claim and any fraud- based claim, three years for the other tort claims, and three or four years for the conspiracy claim, depending on whether it was grounded in tort or fraud.See N.M. Stat. Ann. § 37-1-4 (establishing four-year limitations period for conversion and fraud claims); id.§ 37-1-8 (establishing three-year limitations period for personal injury actions); Peralta v. Peralta, 2006- NMCA 033, 139 N.M. 231, 131 P.3d 81, 84 (N.M. Ct. App. 2005) (applying personal injury statute of limitations period to tortious interference with expected inheritance claim). Based on the factual allegations in the FAC, the court concluded that all of these claims accrued by February 2014, and that because Roberts [**19] did not file his complaint until October 2018, the claims were all time-barred under either a three- or four-year limitations period. In so concluding, the district court rejected Roberts' arguments that the limitations periods did not apply under New Mexico's savings statute and that the claims were timely under the discovery rule. Roberts reasserts those arguments on appeal and we reject them too. New Mexico's savings statute provides: If, after the commencement of an action, the plaintiff fail[s] therein for any cause, except negligence in its prosecution, and [*243] a new suit be commenced within six months thereafter, the second suit shall, for the purposes herein contemplated, be deemed a continuation of the first. N.M. Stat. Ann. § 37-1-14. Relying on this statute, Roberts maintains that his claims were timely because he filed the complaint in this case within six months after the dismissal of the Wyoming suit. The district court disagreed, concluding that the savings statute was inapplicable both because most of Roberts' claims were already time-barred when he filed the Wyoming suit, and because his initial filing in the wrong forum constituted "negligence in prosecution." See Barbeau v. Hoppenrath, 2001- NMCA 077, 131 N.M. 124, 33 P.3d 675, 679 (N.M. Ct. App. 2001) (holding plaintiff's unexcused [**20] failure to file suit in the correct jurisdiction was negligence that precluded application of the savings statute). Roberts take issue with the latter conclusion, maintaining that it was reasonable for him to file suit in Wyoming because he is a Wyoming resident and was in Wyoming when he negotiated the Joint Venture Agreement. But we agree with the district court's determination that, even as a pro se litigant, Roberts could not reasonably have believed Wyoming had personal jurisdiction over the defendants and subject matter jurisdiction over the lawsuit given that none of them lived in or had the requisite contacts with Wyoming and the relevant events all happened in New Mexico. See id. (savings statute inapplicable where the complaint "on its face defeated subject matter jurisdiction," there was no basis for personal jurisdiction over the defendants, and the flawed choice of forum was not "an innocent mistake or an erroneous guess at an elusive jurisdictional fact known only to the defendants or any other circumstance that might serve to excuse what otherwise appears clearly to be negligence"). As for the discovery rule, Roberts maintains he did not discover all of the facts relevant [**21] to the conspiracy and conversion claims until as late as 2018 and that the district court thus erred by dismissing the claims as time-barred. The district court agreed that under the discovery rule, the claims accrued when Roberts knew or should have known the essential facts giving rise to the claims. See State ex rel. Pub. Emps. Ret. Ass'n v. Longacre, 2002- NMSC 033, 133 N.M. 20, 59 P.3d 500, 507 (N.M. 2002) (holding that the accrual date for a New Mexico statute of limitations is "usually . . . the date of discovery"). But the court rejected his 853 Fed. Appx. 235, *242; 2021 U.S. App. LEXIS 11927, **18 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 46 of 106 Page 11 of 13 delayed discovery argument, pointing to the allegations in the FAC that Roberts' excavation began in mid-March 2013, and that the "team was several days into the excavation when [he] discovered that . . . Kemler had tried to hide the [March 6] test results." Aplt. App., Vol. I at 30; see also id. (alleging that after discovering the hidden test results, Roberts found "significant ground disturbance" at what appeared to be the site of the new gold targets). Roberts does not dispute that he discovered the hidden test results in March 2013, and he acknowledges that "the majority of the conspiracies began" in that timeframe. Aplt. Opening Br. at 11. Instead, relying on criminal statutes and caselaw inapplicable here, he contends the conspiracy claim alleged an ongoing [**22] conspiracy that none of the defendants withdrew from, that the conversion "is still happening to this day," id. at 13, and that the statute of limitations did not start running until sometime in 2018, when Roberts learned more details about the defendants' actions.8 Construing [*244] these argument liberally, we assume Roberts is invoking the continuing wrong doctrine, which can be used to toll a statute of limitations. See Tiberi v. Cigna Corp., 89 F.3d 1423, 1431 (10th Cir. 1996) (construing New Mexico law and applying the doctrine to toll the statute of limitations for fraud and negligent misrepresentation). HN7[] Under the continuing wrong doctrine, "where a tort involves a continuing or repeated injury, the cause of action accrues at, and limitations begin to run from, the date of the last injury." Id. at 1430. But "the doctrine cannot be employed where the plaintiff's injury is definite and discoverable, and nothing prevented the plaintiff from coming forward to seek redress." Id. at 1431 (internal quotation marks omitted). Roberts does not dispute that he knew in March 2013 that Patterson and Kemler had located the two additional gold targets and tried to hide the test 8 The district court did not expressly address the ongoing conspiracy and conversion argument in its dismissal orders, but implicitly rejected it in concluding that the claims were time-barred. results, and the allegations in the FAC establish that by February 2014, he knew treasure had been removed from [**23] the property and sold, that the proceeds had been laundered, that he was barred from the Black Mesa, and that none of the defendants intended to include him in any further exploration efforts. Roberts' injury was thus "definite and discoverable" by February 2014. See id. And while he may have learned more details about defendants' alleged wrongdoing between 2014 and 2018, that information did not give rise to a "continuing or repeated injury," as required for tolling under the continuing wrong doctrine. See id. at 1430. Because Roberts knew the essential facts underpinning these claims no later than February 2014 and did not file this lawsuit until October 2018, the district court correctly dismissed the claims as time-barred. Finally, we acknowledge Roberts' one-sentence argument that the district court erred by denying his request under Fed. R. Civ. P. 60(b) to reopen discovery and to allow him to "submit newly discovered evidence . . . that was paramount in helping prove" his conspiracy and conversion claims. Aplt. Opening Br. at 16. We decline to address this unsupported and conclusory claim. See Fed. R. App. P. 28(a)(8)(A) (requiring citations to authorities supporting each argument); Bronson v. Swensen, 500 F.3d 1099, 1104 (10th Cir. 2007) (declining to consider arguments inadequately presented [**24] in appellant's opening brief). In any event, new facts about the substance of the claims would not have affected the district court's conclusion that the claims were time-barred. 5. Dismissal of Conspiracy Claim as Not Separately Actionable The district court also dismissed the conspiracy claim on the ground that under New Mexico law, civil conspiracy is not actionable as a separate claim.See Ettenson v. Burke, 2001- NMCA 003, 130 N.M. 67, 17 P.3d 440, 445, 448 (N.M. 2000) (explaining that civil conspiracy is a "derivative claim" that "requires an overt tortious act independent of the conspiracy," and that "[w]ithout an actionable civil case against one of the 853 Fed. Appx. 235, *243; 2021 U.S. App. LEXIS 11927, **21 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 47 of 106 Page 12 of 13 conspirators, . . . an agreement, no matter how conspiratorial in nature, is not a separate, actionable offense" (internal quotation marks omitted)). Roberts challenges that ruling, but because we have concluded the court properly dismissed the claim as time-barred, we need not address the parties' arguments about this alternative basis for dismissal. See Trevizo v. Adams, 455 F.3d 1155, 1160 n.3 (10th Cir. 2006). 6. Grant of Summary Judgment Without a Hearing Roberts does not challenge the substance of the district court's summary judgment order but argues that the court erred by denying his request for a hearing on the motion. HN8[] An evidentiary hearing is [*245] not required [**25] when the plaintiff's claims can be decided as a matter of law and the parties' pleadings establish that the defendants are entitled to summary judgment. See Kennedy v. Meacham, 540 F.2d 1057, 1061 n.3 (10th Cir. 1976) (explaining that a hearing "is [not] required in every instance"). Roberts maintains that a hearing would have been "beneficial," Aplt. Opening Br. at 16, but he has not established that a hearing was necessary and that the district court abused its discretion by not holding one. 7. Denial of Motion for Preliminary Injunction After the district court entered its orders dismissing most of Roberts' claims against most defendants, he filed a motion seeking an injunction to prevent the removal of any gold and artifacts from Black Mesa until the case was fully litigated in both the district court and on appeal. The district court denied the motion, concluding Roberts had not shown a likelihood of success on the merits. See Colorado v. United States EPA, 989 F.3d 874, 883 (10th Cir. 2021) (setting forth requirements for obtaining preliminary injunction that changes the status quo). HN9[] Roberts takes issue with that ruling, but his appeal of that order is moot given that the district court has entered a final judgment on the merits and the effective time period of the requested injunction has passed. See [**26] United States ex rel. Bergen v. Lawrence, 848 F.2d 1502, 1512 (10th Cir. 1988) (explaining that a preliminary injunction is by its nature a temporary measure intended to furnish provisional protection while awaiting a final judgment on the merits and that entry of final judgment mooted appeal of preliminary injunction); Baker v. Bray, 701 F.2d 119, 122 (10th Cir. 1983) (dismissing appeal of preliminary injunction ruling as moot where district court later dismissed the underlying claim). 8. Additional Issues Roberts asks this court to "prevent . . . Patterson from making threats to [Roberts'] witnesses" and "posting derogatory statements about . . . Roberts" on social media. Aplt. Opening Br. at 26. This court does not have jurisdiction to order such relief. Accordingly, the request is denied. The Cook Defendants argue that this appeal is frivolous and seek an award of damages and costs under Fed. R. App. P. 38, and attorney's fees under 28 U.S.C. § 1927.Initially, we note that there is a split "among the circuits on the question whether § 1927 applies to pro se litigants." See Alexander v. United States, 121 F.3d 312, 316 (7th Cir. 1997).HN10[] Although we have not squarely decided that question, we have commented that § 1927 "is a natural outgrowth of the inherent authority of a court to assess costs and attorney's fees against a party who has acted in bad faith, vexatiously, wantonly, or for oppressive reasons" and that [**27] "awards under § 1927 are made only against attorneys." Hutchinson v. Pfeil, 208 F.3d 1180, 1186 n.9 (10th Cir. 2000) (ellipsis and internal quotation marks omitted). In any event, the decision whether to impose sanctions for a frivolous appeal is discretionary, see Roth v. Green, 466 F.3d 1179, 1188 (10th Cir. 2006), and we decline to do so here. Conclusion The district court's dismissal and summary 853 Fed. Appx. 235, *244; 2021 U.S. App. LEXIS 11927, **24 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 48 of 106 Page 13 of 13 judgment orders are affirmed. Entered for the Court Bobby R. Baldock Circuit Judge End of Document 853 Fed. Appx. 235, *245; 2021 U.S. App. LEXIS 11927, **27 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 49 of 106 Positive As of: October 8, 2021 1:55 AM Z Robinette v. Schirard United States District Court for the District of Colorado February 11, 2014, Decided; February 11, 2014, Filed Civil Action No. 10-cv-02172-CMA-KLM Reporter 2014 U.S. Dist. LEXIS 42747 * BONNER ROBINETTE, and SHIRLEY ROBINETTE, Plaintiffs, v. SYDNEY "DUKE" SCHIRARD, Sheriff, La Plata County Colorado, in his individual and professional capacities, ROBIN HARRINGTON, Under Sheriff, in her individual and professional capacities, BOBBIE FENDER, in his individual and professional capacities, AMBER FENDER, in her individual and professional capacities, STEVE SCHMIDT, in his individual and professional capacities, SEAN SMITH, in his individual and professional capacities, MARTIN PETRIK, in his individual and professional capacities, ROBERT PHIPPEN, in his individual and professional capacities, CHARLES HAMBY, in his individual and professional capacities, SHELLY WILLIAMS, in her individual and professional capacities, TODD HUTCHINS, in his individual and professional capacities, CHRIS BURKE, in his individual and professional capacities, MATT WEBB, in his individual and professional capacities, BRENDA TEBRINK, in her individual and professional capacities, LUCIA SCHIRARD, (911 Dispatch), in her individual and professional capacities, RICHARD GRAEBER, Pine River E.M.T., in his individual and professional capacities, PAUL KOSNIK, County Attorney, in his individual and professional capacities, KELLIE HOTTER, Past County Commissioner, in her individual and professional capacities, WALLY WHITE, Past County Commissioner, in his individual and professional capacities, BOBBIE LIEB, Past and Present County Commissioner, in his individual and professional capacities, BOARD OF COUNTY COMMISSIONERS, GWEN LIEB, Member of the Present Board of County Commissioners, in her individual and professional capacities, JULIE WESTENDOR, Member of the Present Board of County Commissioners, in her individual and professional capacities, and PHIL CAMPBELL, Head of 911 Dispatch, in his individual and professional capacities, Defendants. Subsequent History: Adopted by, Motion granted by, in part, Motion denied by, in part, Dismissed by, in part, Motion granted by, Objection overruled by Robinette v. Schirard, 2014 U.S. Dist. LEXIS 39239 (D. Colo., Mar. 25, 2014) Prior History:Robinette v. Schirard, 2011 U.S. Dist. LEXIS 134958 (D. Colo., Nov. 22, 2011) Core Terms allegations, recommends, conspiracy, statute of limitations, cause of action, incident report, due process claim, law enforcement, dismissal with prejudice, discriminatory, deprivation, outrageous, accrued, emotional distress, rights, common law conspiracy, motion to dismiss, newly-named, ambulance, two-year, opportunity to amend, conspiracy claim, attorney's fees, fraud claim, state law, pro se, non-conclusory, non-defendants, futile, guns Counsel: [*1] Bonner Robinette, Plaintiff, Pro se, Bayfield, CO. Shirley Robinette, Plaintiff, Pro se, Bayfield, CO. For Bobbie Fender, in his professional capacity, Bobbie (I) Fender, in his individual capacity, Amber Fender, in her professional capacity, Amber (I) Fender, in her individual capacity, Steve Schmidt, in his professional capacity, Steve (I) Schmidt, in his individual capacity, Sean Smith, in his professional capacity, Sean (I) Smith, in his individual capacity, Charles Hamby, in his professional capacity, Charles (I) Hamby, in his Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 50 of 106 Page 2 of 14 individual capacity, Sydney (I) Schirard, in his individual capacity, also known as, Duke Schirard, Sydney Schirard, Sheriff of La Plata County Colorado, in his professional capacity, also known as, Duke Schirard, Todd Hutchins, in his professional capacity, Todd (I) Hutchins, in his individual capacity, Defendants: Jonathan Ariel Cross, Sean James Lane, Cross Liechty Lane, P.C., Greenwood Village, CO. For Robin Harrington, Under Sheriff, in her professional capacity, Robin (I) Harrington, in her individual capacity, Robert Phippen, in his professional capacity, Robert (I) Phippen, in his individual capacity, Shelly Williams, in her professional capacity, Shelly [*2] (I) Williams, in her individual capacity, Chris Burke, in his professional capacity, Chris (I) Burke, in his individual capacity, Matt Webb, in his professional capacity, Matt (I) Webb, in his individual capacity, Brenda Tebrink, in her professional capacity, Brenda (I) Tebrink, in her individual capacity, Pauk Kosnik, County Attorney, in his professional capacity, Paul (I) Kosnik, in his individual capacity, Board of County Commissioner's, (Bobbie Lieb) (Gwen Lachelt) (Julie Westendor) Present Board of County Commisioner's [sic] in their professional capacities, Board of County Commissioner's (I), in their individual capacities, Defendants: Jonathan Ariel Cross, Cross Liechty Lane, P.C., Greenwood Village, CO. For Lucia Schirard, (911 Dispatch) in her professional capacity, Lucia (I) Schirard, in her individual capacity, Phil Campbell, (Head of 911 Dispatch) in his professional capacity, Phil (I) Campbell, in his individual capacity, Defendants: Joshua William Mack, LEAD ATTORNEY, Michael Andrew Goldman, Goldman, Robbins & Nicholson, P.C., Durango, CO. For Rich Graeber, Pine River E.M.T., in his professional capacity, Rich (I) Graeber, in his individual capacity, Defendants: Kathleen [*3] Jo Johnson, Thomas Neville Alfrey, Treece Alfrey Musat, P.C., Denver, CO. Judges: Kristen L. Mix, United States Magistrate Judge. Opinion by: Kristen L. Mix Opinion RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE ENTERED BY MAGISTRATE JUDGE KRISTEN L. MIX This matter is before the Court on the Motion to Dismiss Second Amended Complaint [#139],1 filed by Defendants Sydney "Duke" Schirard ("Schirard"), Bobbie Fender, Amber Fender, Steve Schmidt ("Schmidt"), Charles Hamby ("Hamby"), and Sean Smith ("Smith");2 on the Motion to Dismiss Second Amended Complaint for Newly Added Defendants [#151], filed by Defendants Robin Harrington ("Harrington"), Matt Webb ("Webb"), Robert Phippen ("Phippen"), Shelly Williams ("Williams"), Chris Burke ("Burke"), Bobbie Lieb ("Lieb"), Gwen Lachelt ("Lachelt"),3 Julie Westendor ("Westendor"), Paul Kosnik ("Kosnik"), and Brenda Tebrink ("Tebrink");4 on the Motion to Dismiss [#176], filed by Defendant Todd Hutchins ("Hutchins");5 and on the Motion to Dismiss Plaintiffs' Second Amended Complaint [#190], filed by Defendant Rich Graeber ("Graeber").6 Pursuant to 28 U.S.C. § 636(b)(1) and D.C.Colo.LCivR 72.1C.(3), the Motions have been referred to this Court for recommendation [#140, #152, #179, [*4] #191]. The Court has reviewed the Motions, Plaintiffs' Responses, 1 "[#139]" is an example of the convention the Court uses to identify the docket number assigned to a specific paper by the Court's case management and electronic case filing system (CM/ECF). This convention is used throughout this Recommendation. 2 Plaintiffs filed a Response [#156], and these Defendants filed a Reply [#173]. 3 She is identified as "Gwen Lieb" in the Second Amended Complaint. 4 Plaintiffs filed a Response [#175], and these Defendants filed a Reply [#184]. 5 Plaintiffs filed a Response [#189], and Defendant Hutchins filed a Reply [#192]. 6 Plaintiffs filed a Response [#200], and Defendant Graeber filed a Reply [#205]. 2014 U.S. Dist. LEXIS 42747, *1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 51 of 106 Page 3 of 14 Defendants' Replies, the entire docket, and the applicable law, and is sufficiently advised in the premises.7 For the reasons set forth below, the Court respectfully RECOMMENDS that Motion [#139] be GRANTED in part and DENIED in part and that Motions [#151, #176, #190] be GRANTED. I. Background Based on the following alleged events, Plaintiffs8 assert seven causes of action: (1) violation of due process and equal protection, pursuant to 42 U.S.C. § 1983; (2) violation of 42 U.S.C. § 1985(3) (conspiracy); (3) fraud by omission and nondisclosure; (4) attorney's fees under 42 U.S.C. § 1988; (5) negligent infliction of emotional distress ("NIED"); (6) intentional infliction of emotional distress ("IIED"); and (7) common law conspiracy. Second Am. Compl. [#129] at 2. On August 24, 2008, Defendants Bobbie Fender, Amber Fender, and Steven Schmidt (all deputies with the La Plata County Sheriff's Office ["LPCSO"]) took Plaintiffs' Jeep, scaffolding, ladders, heavy-duty extension cords, and other items from Plaintiffs' property and cabin. Id. at 3-4. That same day, Defendant Smith (a lieutenant with LPCSO) took possession of the stolen property. Id. Plaintiffs assert that some of this property 7 Plaintiffs filed Surreplies [#186, #194, #204, #207] in connection with the Motions. However, surreplies are not contemplated by the Federal Rules of Civil Procedure or the Local Rules of Practice, and thus the Court does [*5] not consider them here. The Court is adequately advised of the issues on the parties' present briefings. 8 Plaintiffs are husband and wife and proceed in this matter as pro se litigants. The Court must construe liberally the filings of pro se litigants. See Haines v. Kerner, 404 U.S. 519, 520-21, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972);Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991).However, the Court should not be the pro se litigants' advocate, nor should the Court "supply additional factual allegations to round out [the pro se litigants'] complaint or construct a legal theory on [their] behalf." Whitney v. New Mexico, 113 F.3d 1170, 1173-74 (10th Cir. 1997) (citing Hall, 935 F.2d at 1110).In addition, pro se litigants must follow [*6] the same procedural rules that govern other litigants. Nielsen v. Price, 17 F.3d 1276, 1277 (10th Cir. 1994). belonged to them and that some belonged to their grandson, who had passed away the previous year.Id. at 4. Plaintiffs assert that this property was eventually either "given away, bartered, [thrown] away[, o]r kept." Id. On August 30, 2008, Plaintiffs called 911 and reported that Jonathan Lakey ("Lakey"), a family relation of Defendants Bobbie Fender and Amber Fender, was threatening Plaintiffs' son Randey Robinette ("Randey"), their daughter Angela Robinette Leath ("Angela"), and Angela's two young children with a pistol. Id. at 6-7. Defendant Hamby (a sergeant with LPCSO) responded to the call and told Randey and Angela that he would arrest Mr. Lakey. Id. at 7. [*7] However, when Defendant Hamby discovered that Mr. Lakey was related to the Fenders, Mr. Lakey was merely given a summons. Id. On some unspecified date, Defendant Hamby sent an email to Defendant Bobbie Fender, Defendant Burke (another deputy with LPCSO), and others stating, "[I]f any of the Robinette family are in the area that is argued by the [Robinettes] to be an easement given to the [Robinettes] by E.L. Hutchison (developer), [t]hey are to summons the person(s) for third degree criminal trespass[.] [I]f the [Robinettes] decide to access this area in question it would be through the creek or by helicopter." Id. Plaintiffs assert that this command effectively keeps them from their own property and has been in effect for more than three-and-a-half years.Id. In response to the alleged theft of the Jeep and other items, Plaintiffs called the Colorado State Patrol ("CSP"). Id. On August 31, 2008, Defendant Petrik (a captain with CSP) arrived and proceeded to write and file an allegedly false incident report to cover up the actions of other Defendants in this matter.Id. at 4-5. Plaintiffs assert that a total of six reports with false information were filed in connection with the theft [*8] of their property. Id. at 5-6. These reports were written or falsified by Defendants Hamby, Williams, Amber Fender, Bobbie Fender, Phippen, Tebrink, Schmidt, and Smith, as well as non-defendants G. Little, D. Martin, and V. Kirkpatrick. Id. at 5-6. 2014 U.S. Dist. LEXIS 42747, *4 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 52 of 106 Page 4 of 14 On March 16, 2009, Plaintiffs called 911 to request an ambulance for Plaintiff Shirley Robinette ("Mrs. Robinette"), who was allegedly "having a negative reaction to her reading false reports," specifically regarding four incident reports that listed Plaintiffs' deceased grandson as a "victim" even though he had been dead for more than a year. Id. at 8. Plaintiffs state that no ambulance ever came in response to their call, so Plaintiff Bonner Robinette ("Mr. Robinette") told the 911 operator to send an ambulance to meet his son Randey, who was bringing Mrs. Robinette to the hospital. Id. Plaintiffs state that no emergency personnel or anyone from LPCSO ever met up with Randey and Mrs. Robinette. Id. Plaintiffs assert that Defendant Graeber, the former Head of Upper Pine River EMT, was responsible for failing to send an ambulance. Id. at 12. On April 12, 2009, Plaintiffs called LPCSO to report a trespasser on their property. Id. at 9. Plaintiffs [*9] state that Defendant Burke did not come in response to their call.9 Id. The associated sheriff's incident report stated that there were guns at the residence and that threats were made against law enforcement.10 Id. On April 17, 2009, Plaintiffs met with Deputy Kevin Brown ("Brown"), a non-defendant, at LPCSO. Id. at 9. Plaintiffs provided him with more than one hundred pages demonstrating alleged illegal actions taken by LPCSO.11 Id. Deputy Brown told his supervisor, Defendant Hutchins, that he was going to take the documents to the District Attorney's Office, but Defendant Hutchins refused to allow him to do so. Id. Deputy Brown took the 9 Plaintiffs allege at various points in the Second Amended Complaint that a particular law enforcement officer or officers did not come to their property in response to their telephone calls. Plaintiffs do not make clear why they believe these particular individuals should have responded to their calls. However, this lack of clarity does not affect the resolution of the pending Motions. 10 As with subsequent incident reports containing this language, the reports are unclear as to who allegedly had guns and who was allegedly threatening police. 11 The Second Amended Complaint does not explain whether the alleged illegal actions were directed at Plaintiffs, others, or both. paperwork [*10] to the District Attorney's Office anyway, but officials there refused to take possession of the materials. Id. On May 20, 2009, Mr. Robinette called 911 multiple times to get an ambulance to take Mrs. Robinette to the hospital "due to her being in a semi-coma for 22 hours" from a complication following a brain operation on May 5, 2009. Id. Plaintiffs state that they pleaded for help but that no one responded. Id. They also assert that Defendant Graeber was again responsible for failing to send an ambulance. Id. at 12. Mr. Robinette eventually drove Mrs. Robinette to the hospital "with his emergency flashing lights on" as he continued to contact 911 to ask them to tell LPCSO that he was trying to get his wife to the hospital. Id. Although Mr. Robinette was seeking a law enforcement escort, the 911 dispatcher told him that they could not provide that service. Id. at 8-9. On November 3, 2009, Plaintiffs called LPCSO on a "Citizen Assist Request" to report that unidentified family members of LPCSO officers "would not allow the Plaintiffs['] renters to remove their [*11] personal [b]elongings off their property and[/]or to obtain their dogs out of their RV home." Id. at 10. Plaintiffs assert that Defendant Burke never came in response to this call. Id. In mid-February 2010, Plaintiffs met with Defendant Hotter (a La Plata County Commissioner) at her office in the La Plata County Court House to show her evidence of alleged wrongdoing by Defendant Schirard (the Sheriff of La Plata County), Defendant Harrington (the Undersheriff of La Plata County), and other deputies. Id. at 13. Defendant Hotter thereafter set up a meeting with Plaintiffs, two newspapers reporters, and Defendant Schirard, but Defendant Schirard did not attend the meeting. Id. Plaintiffs assert that Defendant Hotter conveyed to Defendants White and Lieb (two other County Commissioners) the information regarding the alleged wrongdoing by Defendant Schirard, Defendant Harrington, and other deputies. Id. On March 3, 2010, Plaintiffs called LPCSO "to report two suspicious males who were 2014 U.S. Dist. LEXIS 42747, *8 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 53 of 106 Page 5 of 14 [t]respassing" on their property. Id. at 10. Defendant Webb (another deputy with LPCSO) and Defendant Burke did not come in response to the call. Id. The incident report written in connection with Plaintiffs' [*12] call stated that there were guns at the residence and that law enforcement had been threatened. Id. On August 24, 2010, Plaintiffs filed this lawsuit. On December 4, 2010, Plaintiffs called LPCSO "to report a criminal [t]respass/[t]heft/[b]urglary to the Robinette-Leaths['] [c]abin." Id. at 10-11. Deputy J. Sutter ("Sutter") and Deputy B. Potthoff (non- defendants) responded and investigated. Id. at 11. Mrs. Robinette and her son Randey later picked up a copy of the incident report from LPCSO, and it included the language about guns at the residence and that law enforcement had been threatened. Id. When Mrs. Robinette noticed these statements, she and Randey took the report back to LPCSO and showed it to Defendant Tebrink (an LPCSO employee who worked at the records counter). Id. Defendant Tebrink took the report, went to her office, and returned with a copy of the report that did not have the alert codes on them regarding guns and threats. Id. Randey asked Defendant Tebrink for the first report, but Plaintiffs allege that she stepped back, laughed, said "You're not getting this one back," and tore it up and threw it in the trash. Id. On January 27, 2012, Plaintiffs called 911 to report [*13] gunshots at their residence. Id. at 11. Their son Randey was standing outside in their yard about thirty feet from the trees "when bullets [went] whistling above his head hitting the tree limbs." Id. Deputy Sutter and Deputy R. McLaughlin (non- defendants) did not come in response to the call, although Deputy Sutter called Plaintiffs to say he investigated the incident. Id. The incident report again stated that there were guns at the residence and that law enforcement had been threatened. Id. at 12. On March 8, 2012, Mr. Robinette called LPCSO to report that unidentified family members of LPCSO were trespassing on his property. Deputy Jim Coleman (a non-defendant) did not come in response to Plaintiffs' call. Id. at 12. Plaintiffs assert that the related incident report "shows blobs of white out covering up the suspect's name," and that when Mr. Robinette called Defendant Kosnik (an assistant county attorney) at his office to inquire about it, Defendant Kosnik's secretary told him that Defendant Kosnik had covered up the name.Id. at 12-13. On April 4, 2013, Plaintiffs visited the La Plata County Court House. Id. at 6. They state that Defendant Hamby saw them there, got on the elevator [*14] with them, sat behind Plaintiffs in the courtroom, and rode back down in the elevator with them when they left. Id. "Plaintiffs thought this was to intimidate" them. Id. II. Standard of Review The purpose of a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) is to test "the sufficiency of the allegations within the four corners of the complaint after taking those allegations as true." Mobley v. McCormick, 40 F.3d 337, 340 (10th Cir. 1994);Fed R. Civ. P. 12(b)(6) (A complaint may be dismissed for "failure to state a claim upon which relief can be granted."). "The court's function on a Rule 12(b)(6) motion is not to weigh potential evidence that the parties might present at trial, but to assess whether the plaintiff's complaint alone is legally sufficient to state a claim for which relief may be granted." Sutton v. Utah State Sch. for the Deaf & Blind, 173 F.3d 1226, 1236 (10th Cir. 1999) (citation omitted). To withstand a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), "a complaint must contain enough allegations of fact 'to state a claim to relief that is plausible on its face.'" Robbins v. Oklahoma, 519 F.3d 1242, 1247 (10th Cir. 2008) [*15] (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007)); see also Shero v. City of Grove, 510 F.3d 1196, 1200 (10th Cir. 2007) ("The complaint must plead sufficient facts, taken as true, to provide 'plausible grounds' that discovery will reveal evidence to support the plaintiff's allegations." (quoting Twombly, 550 U.S. at 570))."A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable 2014 U.S. Dist. LEXIS 42747, *11 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 54 of 106 Page 6 of 14 for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009). "A pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do. Nor does a complaint suffice if it tenders naked assertions devoid of further factual enhancement." Id. (internal quotation marks and citation omitted). The factual allegations in the complaint "must be enough to raise a right to relief above the speculative level." Christy Sports, LLC v. Deer Valley Resort Co., 555 F.3d 1188, 1191 (10th Cir. 2009). "[W]here the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct," a factual allegation has been stated, "but [*16] it has not shown that the pleader is entitled to relief," as required by Federal Rule of Civil Procedure 8(a).Iqbal, 556 U.S. at 679 (quotation marks and citation omitted). III. Analysis A. Statute of Limitations On June 21, 2013, Plaintiffs filed their Second Amended Complaint, which named as defendants for the first time Defendants Petrik, Phippen, Williams, Hutchins, Burke, Webb, Tebrink, Graeber, Kosnik, Hotter, White, Lieb, Lachelt, Westendor, and the past and present Board of County Commissioners of La Plata County. These Defendants assert that Plaintiffs' claims against them fail based on the statute of limitations. Actions brought pursuant to 42 U.S.C. § 1983 are subject to the general personal injury limitation period of the state in which the action arose. Hunt v. Bennett, 17 F.3d 1263, 1265 (10th Cir. 1994).In Colorado, the limitation on a personal injury claim brought pursuant to § 1983 is two years. See Colo. Rev. Stat. § 13-80-102(1)(g) (creating a two-year limitation period for "[a]ll actions upon liability created by a federal statute where no period of limitation is provided in said federal statute" and for "[a]ll other actions of every kind for which no other period [*17] of limitation is provided"); see Blake v. Dickason, 997 F.2d 749, 750 (10th Cir. 1993) (applying Colo. Rev. Stat. § 13-80-102 to a § 1983 claim). Thus, as to these newly-named Defendants, there is a two-year statute of limitations for Plaintiffs' claims under 42 U.S.C. §§ 1983 and 1985 as well as for NIED, IIED, and common law conspiracy.12 See Alvarez v. Sandridge, 149 F. App'x 822, 823 (10th Cir. 2005) (affirming two-year statute of limitations in Colorado on a § 1985(3) claim); Colo. Rev. Stat. § 13-80-102(1)(a) (specifically stating that negligence causes of action are subject to a two- year state of limitations); Patterson v. Dex Media, Inc., No. 11-cv-02336-LTB-BNB, 2013 U.S. Dist. LEXIS 8354, 2013 WL 229575, at *3 (D. Colo. Jan. 22, 2013) (applying Colorado two-year statute of limitations to IIED claim); Gartin v. Spyderco, No. CIV.NO. 95-B-1747, 1997 U.S. Dist. LEXIS 24518, 1997 WL 1037883, at *13 (D. Colo. Aug. 13, 1997) (applying Colorado's two-year statute of limitations to a common law conspiracy claim). However, federal law rather than state law determines when a cause of action accrues. Indus. Constructors Corp. v. U.S. Bureau of Reclamation, 15 F.3d 963, 968 (10th Cir. 1994). [*18] Federal law provides that "[t]he statute of limitations begins to run when the plaintiff knows or has reason to know of the existence and cause of the injury which is the basis of his action." Id. at 969. That is, "[a] civil rights action accrues when facts that would support a cause of action are or should be apparent." Fratus v. Deland, 49 F.3d 673, 675 (10th Cir. 1995) (citations omitted). This means that the federal causes of action must have accrued on or after June 21, 2011. Colorado law is similar for the state law causes of action. "[A] cause of action for injury to person, property, reputation, possession, relationship, or status shall be considered to accrue on the date both the injury and its cause are known or should have been known by the exercise of reasonable diligence." Colo. Rev. Stat. § 13-80-108(1);see Murry v. GuideOne Specialty Mut. Ins. Co., 194 P.3d 489, 492 (Colo. App. 2008). Thus, Plaintiffs' claims of NIED, IIED, and common law conspiracy also must have accrued on or after June 21, 2011. The only 12 The Court discusses Plaintiffs' fraud claim below, as it has a different statute of limitations. 2014 U.S. Dist. LEXIS 42747, *15 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 55 of 106 Page 7 of 14 newly-named Defendant against whom any allegations are made about events allegedly occurring after June 21, 2011 is Defendant Kosnik. Turning to Plaintiffs' claim [*19] of fraud against the newly-named Defendants, under Colorado law, the statute of limitations for fraud and misrepresentation claims is three years after the cause of action accrues. Colo. Rev. Stat. § 13-80- 101(1)(c) & (f) (2008). Fraud and misrepresentation claims accrue when the plaintiff begins to suffer some injury as a result of his or her reliance on the misrepresentation or fraud. Duell v. United Bank of Pueblo, 892 P.2d 336, 340 (Colo. App. 1994). This means that this cause of action must have accrued on or after June 21, 2010 for the newly-named Defendants. Besides Defendant Kosnik, the only newly-named Defendant for whom any allegations are made about events that occurred after June 21, 2010, is Defendant Tebrink. Plaintiffs argue that the statutes of limitations should be tolled as to their claims because under 42 U.S.C. § 14141, they have alleged a pattern and practice of misconduct by law enforcement officers. However, 42 U.S.C. § 14141 "provides for a civil cause of action only available to the Attorney General." Adams v. United States, 82 Fed. Cl. 558, 560 (Fed. Cl. 2008). Moreover, section 14141 does not include any provision for tolling the statute of limitations in [*20] these circumstances, especially for the many newly-named Defendants who are not law enforcement officers. Plaintiffs also argue that the statutes of limitations should be tolled because of Plaintiffs' poor health and resultant "legal disability." Colorado law defines a "person under disability" as "any person who is a minor under eighteen years of age, a mental incompetent, or a person under other legal disability and who does not have a legal guardian." Colo. Rev. Stat. § 13- 81-101. However, Plaintiffs have made only conclusory allegations that they fall within the meaning of this statute and that their age and health create a "legal disability."13 Thus, the Court 13 Moreover, the Court finds it strange that Plaintiffs would discharge their former pro bono attorneys if they believe they suffer from a legal disability. Refusing competent, free legal rejects Plaintiffs' arguments that the statutes of limitations should be tolled. Accordingly, the Court recommends that the following claims be dismissed with prejudice against [*21] the following Defendants on the basis of the relevant statutes of limitations: Claims I, II, IV, V, VI, and VII against Defendants Petrik, Phippen, Williams, Hutchins, Burke, Webb, Tebrink, Graeber, Hotter, White, Lieb, Lachelt, Westendor, and the past and present Board of County Commissioners of La Plata County; and Claim III against Defendants Petrik, Phippen, Williams, Hutchins, Burke, Webb, Graeber, Hotter, White, Lieb, Lachelt, Westendor, and the past and present Board of County Commissioners of La Plata County.14 Gee v. Pacheco, 627 F.3d 1178, 1181 (10th Cir. 2010) (affirming dismissal with prejudice of claims as barred by statute of limitations). Thus, Claims I, II, III, IV, V, VI, and VII against Defendant Kosnik and Claim III against Defendant Tebrink are not subject to dismissal on the basis of statute of limitations. B. [*22] Section 1983 Plaintiffs assert violations of both due process and equal protection in connection with their claim under 42 U.S.C. § 1983. 1. Due Process Procedural due process protects the individual against "arbitrary action of government." Wolff v. McDonnell, 418 U.S. 539, 557, 94 S. Ct. 2963, 41 L. Ed. 2d 935 (1974). In general, a plaintiff must make two showings in order to proceed on a advice is always worrisome, but it is especially troubling when Plaintiffs contend that they are disadvantaged in pursuing their own legal rights. See Order [#120]. 14 It is unclear whether Plaintiffs may have been trying to assert claims against La Plata County or county officials based on the alleged bad actions of LPCSO and its employees. To the extent that they were, the Court notes that under Colorado law, the Sheriff, and not the County is responsible for the actions of his deputies. See Tunget v. Bd. of Cnty. Comm'rs, 992 P.2d 650, 652 (Colo. App. 1999). 2014 U.S. Dist. LEXIS 42747, *18 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 56 of 106 Page 8 of 14 procedural due process claim. See Bartell v. Aurora Pub. Sch., 263 F.3d 1143, 1149 (10th Cir. 2001). First, a plaintiff must demonstrate that he possesses a protected liberty or property interest. Id. Second, a plaintiff must show that the procedures which impacted his protected interest were inadequate under the circumstances. Id. at 1149. A portion of this original claim remains from Plaintiffs' Amended Complaint. On July 24, 2012, the District Judge permitted the portion of this claim alleging the retention of Plaintiffs' personal property at the Sheriff's Department to move forward.15 Order [#66] at 5. Although Plaintiffs' allegations have changed somewhat in the Second Amended Complaint, the Court finds that they have stated a § 1983 due process claim against certain Defendants: Bobbie Fender, Amber Fender, Schmidt, and Smith. [*23] The allegations supporting this claim are that Defendants Bobbie Fender, Amber Fender, and Schmidt stole the Jeep and other property from Plaintiffs, that Defendant Smith received the stolen property from them that same day, and that all of these Defendants performed these acts through the use of their authority and their badge. Second Am. Compl. [#129] at 3-4. This is sufficient to state a due process claim at this stage of the litigation.16 See Order [66] at 5. The allegations against Defendants Schirard, Tebrink, and Kosnik are insufficient to state a due process claim against them. Plaintiffs make no 15 The District Judge originally held that any violation (including the seizure of the property) prior to September 7, 2008 was barred by the statute of limitations, but on a motion for reconsideration, this date was revised to August 24, 2008, the date of the alleged theft. Order [#66] at 2-3. 16 The Court acknowledges that, unlike in the Amended Complaint, in the Second Amended Complaint Plaintiffs have alleged facts in support of a due process claim for both the taking and the retention of the Jeep and other property. See Order [#66] at 5 (finding that Plaintiffs' did not state a due process claim regarding the actual taking of the property because of allegations that Defendants were "in plain clothes" and "not in uniform"). [*24] Here, Plaintiffs clearly allege that these Defendants took Plaintiffs' property under color of state law. non-conclusory allegations about the actions of Defendant Schirard except that he did not attend a meeting set up by Defendant Hotter. See, e.g., Second Am. Compl. [#129] at 2 (stating that Defendant Schirard "harmed each Plaintiff Bonner and Shirley Robinette from 08-24-08 to the present by [his] failure to hold each Defendant accountable for their unlawful[ ] bias, prejudice[ ], and animosities"). To the extent that Plaintiffs seek to impose direct individual liability on Defendant Schirard, the Court notes that individual liability pursuant to § 1983 "must be based on personal involvement in the alleged constitutional violation." Foote v. Spiegel, 118 F.3d 1416, 1425, (10th Cir. 1997); (citing Grimsley v. MacKay, 93 F.3d 676, 679 (10th Cir. 1996)); Bennett v. Passic, 545 F.2d 1260, 1262-63 (10th Cir.1976) ("Personal participation is an essential allegation in a Section 1983 claim." (citations omitted)). Plaintiffs have failed to allege [*25] Defendant Schirard's personal involvement in any due process violation. Similarly, to the extent that Plaintiffs seek to impose supervisory liability on Defendant Schirard, they must demonstrate an "affirmative link" between the supervisor and the alleged constitutional violation. Schneider v. City of Grand Junction Police Dep't, 717 F.3d 760, 768 (10th Cir. 2013) (citing Dodds v. Richardson, 614 F.3d 1185, 1195 (10th Cir. 2010)).The affirmative link requires more than "a supervisor's mere knowledge of his subordinate's" conduct. Schneider, 717 F.3d at 768 (quoting Iqbal, 556 U.S. at 677). Three elements are required to establish a section 1983 claim against a defendant based on his supervisory responsibilities: (1) personal involvement, (2) sufficient causal connection, and (3) culpable state of mind. Schneider, 717 F.3d at 768 (citing Dodds, 614 F.3d at 1195). Plaintiffs fail to make allegations which satisfy these elements in the Second Amended Complaint. Turning to Defendants Tebrink and Kosnik, the non-conclusory allegations against Defendant Tebrink are that she gave Mrs. Robinette and her son a copy of an incident report, and that when they returned the incident report to her, [*26] she 2014 U.S. Dist. LEXIS 42747, *22 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 57 of 106 Page 9 of 14 destroyed it and gave them an amended version instead. Id. at 11. The non-conclusory allegation against Defendant Kosnik is that he covered up a suspect's name on an incident report. Id. at 12-13. To the extent that Plaintiffs may have been attempting to assert a due process claim against these individuals for these actions, Plaintiffs have failed to specify the protected liberty or property interest at stake. See Bartell, 263 F.3d at 1149. The Court concludes that Plaintiffs have not sufficiently alleged a liberty or property interest in unadulterated police incident reports. "A liberty interest may arise from the Constitution itself, by reason of guarantees implicit in the word 'liberty,' or it may arise from an expectation or interest created by state laws or policies." Wilkinson v. Austin, 545 U.S. 209, 221, 125 S. Ct. 2384, 162 L. Ed. 2d 174 (2005). Neither the Constitution nor the word 'liberty' create a citizen's right to unadulterated police reports. Plaintiffs point to no state law or policy which creates such a right, or which prevents police and prosecutors from amending or redacting reports. Indeed, the Tenth Circuit Court of Appeals has held that "complaints deal[ing] almost exclusively with procedure [*27] such as police reports [and] responses to calls . . . do not state any constitutional entitlement." Phillips v. Kerns, 483 Fed. App'x 400, 402 (10th Cir. 2012). Moreover, "[a]n entitlement to nothing but procedure cannot serve as the basis for a property right protected by the due process clause."Town of Castle Rock, Colo. v. Gonzales, 545 U.S. 748, 764, 125 S. Ct. 2796, 162 L. Ed. 2d 658 (2005). Because Plaintiffs fail to allege a protected interest, they fail to properly assert that either of these Defendants violated their due process rights. With respect to Defendant Hamby, the non- conclusory allegations against him are that he failed to arrest someone who was threatening Plaintiffs' adult children and their daughter's grandchildren; that he sent an email to certain law enforcement personnel telling them that Plaintiffs and their family would be deemed trespassing if found on a certain disputed parcel of land; and that in the La Plata Court House, he twice rode with Plaintiffs in the elevator and sat behind them in the courtroom.Second Am. Compl. [#129] at 6-7. Taking Plaintiffs' allegations as true, Defendant Hamby's threat to arrest Plaintiffs should they make use of what they claim is their own land may constitute [*28] a taking of property without due process of law. See Soldal v. Cook Cnty, Ill., 506 U.S. 56, 113 S. Ct. 538, 121 L. Ed. 2d 450 (1992) (stating that a property owner's constitutional rights may be violated when law enforcement personnel interfere with the owner's possessory interests in his property). Accordingly, at this early stage of the litigation, the Court finds that Plaintiffs have stated a due process claim against Defendant Hamby. Accordingly, the Court recommends that Plaintiffs' due process claim against Defendants Schirard, Tebrink, and Kosnik be dismissed.17 2. Equal Protection It is well established "that the Constitution prohibits selective enforcement of the law based on considerations such as race." Whren v. United States, 517 U.S. 806, 813, 116 S. Ct. 1769, 135 L. Ed. 2d 89 (1996). To establish a claim of selective law enforcement under § 1983, "[t]he plaintiff must demonstrate that the defendant's actions had a discriminatory effect and were motivated by a discriminatory purpose." Marshall, 345 F.3d at 1168. "[T]he discriminatory purpose element requires a showing that discriminatory intent [*29] was a 'motivating factor in the decision' to enforce the criminal law against the [plaintiff]." United States v. Alcaraz-Arellano, 441 F.3d 1252, 1264 (10th Cir. 2006) (quoting Marshall, 345 F.3d at 1168). First, Plaintiffs make no allegations that they belong to a protected class because of, for example, their race. Second, the standard for proving a selective enforcement claim is a demanding one. Alcaraz-Arellano, 441 F.3d at 1264. "Those seeking to establish an equal protection claim based on selective law enforcement face a high burden: they must dispel the presumption that a law enforcement official has not violated the Equal Protection Clause with 'clear 17 The Court discusses whether this and the remaining claims (discussed below) should be dismissed with or without prejudice in Section III.I. below. 2014 U.S. Dist. LEXIS 42747, *26 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 58 of 106 Page 10 of 14 evidence to the contrary.'" United States v. Hernandez-Chaparro, 357 F. App'x 165, 166 (10th Cir. 2009) (citing United States v. Armstrong, 517 U.S. 456, 465, 116 S. Ct. 1480, 134 L. Ed. 2d 687 (1996)). Police possess broad discretion in determining when to make a traffic stop or arrest. Alcaraz-Arellano, 441 F.3d at 1264. "Judicial interference with law-enforcement discretion might 'induce police officers to protect themselves against false accusations in ways that are counterproductive to fair and effective enforcement of the laws,' such as by directing law [*30] enforcement resources away from minority neighborhoods." Id. (quoting Marshall, 345 F.3d at 1167). Defendants contend that Plaintiffs have made no allegations that they were motivated by a discriminatory purpose or that their actions had a discriminatory effect within the meaning of the equal protection clause.See Marshall, 345 F.3d at 1168. Further, Plaintiffs make no allegations that any criminal laws were actually enforced against them.Alcaraz-Arellano, 441 F.3d at 1264.Rather, Plaintiffs' claims are primarily based on Defendants' alleged failure to provide them with certain services and protection. In that regard, "[i]t is perfectly clear . . . that neither the Federal Constitution itself, nor any federal statute, granted [them] any individual entitlement to police protection." Town of Castle Rock v. Gonzales, 545 U.S. 748, 773, 125 S. Ct. 2796, 162 L. Ed. 2d 658 (2005) (J. Stevens, dissenting, but agreeing with the majority on this point). Based on the foregoing, the Court finds that this claim should be dismissed for failure to state the essential elements of a selective enforcement equal protection claim. Plaintiffs have offered nothing more than conclusions based on speculation and their own subjective beliefs. [*31] There are simply no allegations that Defendants' actions or inactions were motivated by an impermissible discriminatory purpose. Considering both the lack of allegations supporting the significant burden required to show an equal protection violation based on selective law enforcement, the Court finds that Plaintiffs have failed to state an equal protection claim. Accordingly, the Court recommends that Plaintiffs' section 1983 equal protection claim be dismissed. C.42 U.S.C. § 1985(3) Plaintiffs also allege that Defendants engaged in a conspiracy to violate their constitutional rights in violation of 42 U.S.C. § 1985(3). The elements of a § 1985(3) conspiracy claim are: (1) a conspiracy; (2) to deprive plaintiff of equal protection or equal privileges and immunities; (3) an act in furtherance of conspiracy; and (4) an injury or deprivation resulting therefrom. Tilton v. Richardson, 6 F.3d 683, 686 (10th Cir. 1993). The Court has reviewed the Second Amended Complaint and finds that even construing Plaintiffs' allegations liberally and in the light most favorable to them, Plaintiffs have presented nothing more than conclusory allegations in support of this claim. Just as importantly, however, [*32] § 1985(3) only applies to "conspiracies motivated by 'some racial, or perhaps otherwise class-based, invidiously discriminatory animus.'" Tilton, 6 F.3d at 686 (quoting Griffin v. Breckenridge, 403 U.S. 88, 101- 02, 91 S. Ct. 1790, 29 L. Ed. 2d 338 (1971)). "The other 'class-based animus' language of this requirement has been narrowly construed . . ." Id. (citing United Bhd. of Carpenters & Joiners of Am., Local 610, AFL—CIO v. Scott, 463 U.S. 825, 837, 103 S. Ct. 3352, 77 L. Ed. 2d 1049 (1983). As noted above, Plaintiffs make no showing that they are members of a racial or other class that is protected by § 1985(3). Thus, the Court finds that Plaintiffs have not sufficiently alleged facts supporting all of the elements necessary to demonstrate entitlement to relief under this legal theory, and therefore that this claim must be dismissed. See Lane v. Simon, 495 F.3d 1182, 1186 (10th Cir. 2007) (discussing pleading requirements to support legal theory). Accordingly, the Court recommends that Plaintiffs' claim under 42 U.S.C. § 1985(3) be dismissed. D.42 U.S.C. § 1988 Plaintiffs request attorneys' fees and costs. Second 2014 U.S. Dist. LEXIS 42747, *29 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 59 of 106 Page 11 of 14 Am. Compl. [#129] at 2. Pursuant to 42 U.S.C. § 1988, "[i]n any action or proceeding to enforce a provision of sections 1981,1981a,1982, [*33] 1983, 1985, and 1986 of this title . . . the court, in its discretion, may allow the prevailing party . . . a reasonable attorney's fee . . . ." 42 U.S.C. § 1988(b). However, the Tenth Circuit has found that pro se litigants may not recover an award of attorneys' fees pursuant to this statute. Turman v. Tuttle, 711 F.2d 148, 149 (10th Cir. 1983). "This finding seems to comport with the policy underlying § 1983, which appears to have been implemented not to compensate pro se litigants but to enable litigants with valid claims to present their claims without having to bear the burden of the costs." Id. Accordingly, Plaintiffs are not entitled to attorneys' fees pursuant to 42 U.S.C. § 1988, and the Court recommends that Plaintiffs' claim under 42 U.S.C. § 1988 be dismissed. E. Fraud By Omission and Nondisclosure To state a claim of fraud under Colorado law, Plaintiffs must generally allege: "(1) a false representation of a material existing fact; (2) knowledge on the part of the one making the representation that it is false; (3) ignorance on the part of the one to whom the representation is made of falsity; (4) representation made with intention that it be acted upon; [and] (5) representation [*34] resulting in damages." Navigators Specialty Ins. Co. v. Beltman, No. 11-cv-00715-RPM, 2012 U.S. Dist. LEXIS 156666, 2012 WL 5378750, at *6 (D. Colo. Nov. 1, 2012) (quoting Kinsey v. Preeson, 746 P.2d 542, 550 (Colo. 1987)). Further, pursuant to Fed. R. Civ. P. 9(b), "the circumstances constituting fraud or mistake shall be stated with particularity." Here, the basis for Plaintiffs' fraud claim is unclear. Based on a close reading of the Second Amended Complaint, the Court assumes that Plaintiffs may be basing their fraud claim on alleged falsehoods contained in law enforcement incident reports. To the extent Plaintiffs are attempting to allege fraud based on these reports, they fail to meet many of the required elements of the claim. They certainly do not allege that anyone knowingly made a false representation on which they relied. In addition, Plaintiffs fail to "set forth [with sufficient particularity] the who, what, when, where and how of the alleged fraud" and do not sufficiently "set forth the time, place, and contents of the false representation, the identity of the party making the false statements and the consequences thereof." United States ex rel. Sikkenga v. Regence Bluecross Blueshield of Utah, 472 F.3d 702, 727 (10th Cir. 2006) [*35] (citations omitted). Although some of these allegations may be gleaned from the Second Amended Complaint, none are made in such a way as to provide Defendants with fair notice of the basis for this claim against each Defendant. See Robbins v. Oklahoma, 519 F.3d 1242, 1250 (10th Cir. 2008) (stating that when an action is brought against multiple individual governmental actors, "it is particularly important . . . that the complaint make clear exactly who is alleged to have done what to whom, to provide each individual with fair notice as to the basis of the claims against him or her"). Accordingly, the Court recommends that Plaintiff's fraud claim be dismissed pursuant to both Fed. R. Civ. P. 12(b)(6) and Fed. R. Civ. P. 9(b). F. NIED To allege a NIED claim, "a plaintiff must show that the defendant's negligence created an unreasonable risk of physical harm and caused the plaintiff to be put in fear for his or her own safety, that this fear had physical consequences or resulted in long-continued emotional disturbance, and that the plaintiff's fear was the cause of the damages sought." Draper v. DeFrenchi-Gordineer, 282 P.3d 489, 496-97 (Colo. App. 2011). Plaintiffs must also allege that [*36] they either suffered physical injury or were in the "zone of danger." Id. at 497. Here, Plaintiffs have failed to provide any allegations that the actions of Defendants placed them at an "unreasonable risk of physical harm." The Second Amended Complaint contains no non- conclusory allegations that any of Defendants' actions "had physical consequences or resulted in 2014 U.S. Dist. LEXIS 42747, *32 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 60 of 106 Page 12 of 14 long-continued emotional disturbance." Accordingly, the Court recommends that Plaintiffs' NIED claim be dismissed. G. IIED An IIED claim is made under state law. Specifically, "Colorado has adopted the Restatement (Second) of Torts definition of intentional infliction of emotional distress: 'One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress, and if bodily harm to the other results from it, for such bodily harm.'" Han Ye Lee v. Colo. Times, Inc., 222 P.3d 957, 963 (Colo. Ct. App. 2009) (citing Restatement (Second) of Torts § 46(1) (1965)). Thus "[t]he elements of outrageous conduct are: (1) the defendant engaged in extreme and outrageous conduct, (2) recklessly or with the intent of causing the plaintiff severe [*37] emotional distress, and (3) causing the plaintiff severe emotional distress." Pearson v. Kancilia, 70 P.3d 594, 597 (Colo. Ct. App. 2003). Plaintiffs fail to provide any specific allegations in support of their general allegation that Defendants' actions were extreme and outrageous. Extreme and outrageous conduct must be "so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community." Estate of Trentadue ex rel. Aguilar v. United States, 397 F.3d 840, 855 (10th Cir. 2005). Plaintiffs have not sufficiently alleged that Defendants' behavior was outrageous, atrocious, and utterly intolerable in a civilized society. Moreover, "[w]here a complaint pleads facts that are 'merely consistent with' a defendant's liability, it 'stops short of the line between possibility and plausibility of "entitlement to relief."'" Iqbal, 129 S. Ct. at 1950 (quoting Twombly, 550 U.S. at 557). Here, the Court finds that the "well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct." Id. Therefore, the Court agrees that the allegations do not sufficiently [*38] allege the type of conduct that plausibly qualifies as extreme and outrageous. Accordingly, the Court recommends that Plaintiffs' IIED claim be dismissed. H. Conspiracy Plaintiffs also assert a claim of common law conspiracy. Second Am. Compl. [#129] at 2. "To establish a civil conspiracy, a plaintiff must show by a preponderance of the evidence that there exists: (1) an object to be accomplished; (2) an agreement by two or more persons on a course of action to accomplish that object; (3) in furtherance of that course of action, one or more unlawful acts which were performed to accomplish a lawful or unlawful goal, or one or more lawful acts which were performed to accomplish an unlawful goal; and (4) damages to the plaintiff as a proximate result."Magin v. DVCO Fuel Sys., Inc., 981 P.2d 673, 674-75 (Colo. Ct. App. 1999). In light of the Court's analysis above, the only claim not subject to dismissal is a § 1983 due process claim. The Tenth Circuit has stated that "a conspiracy to deprive a plaintiff of a constitutional or federally protected right under the color of state law" is actionable. Snell v. Tunnell, 920 F.2d 673, 701 (10th Cir. 1990).However, in order to succeed on a conspiracy [*39] claim under § 1983, "a plaintiff must plead and prove not only a conspiracy, but also an actual deprivation of rights; pleading and proof of one without the other will be insufficient." Id. Further, "[w]hile a deprivation of a constitutional right is essential to proceed under a § 1983 claim, proof of an agreement to deprive will often require examination of conduct occurring prior to the deprivation." Id. at 701-02. To establish the existence of a conspiracy, a plaintiff seeking redress must show that there was a "single plan, the essential nature and general scope of which [was] known to each person who is to be held responsible for its consequences." Id. (internal citations omitted). The Court appropriately disregards the legal labels applied by pro se plaintiffs when those labels serve to obfuscate the nature of the legal claims asserted.See Castro v. United States, 540 U.S. 375, 381, 124 S. Ct. 786, 157 L. Ed. 2d 778 (2003) (noting that it is appropriate for federal courts to 2014 U.S. Dist. LEXIS 42747, *36 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 61 of 106 Page 13 of 14 ignore the legal labels attached to a pro se party's claims "to create a better correspondence between the substance of [the party's claims] and [the] underlying legal basis"). The thrust of Plaintiff's conspiracy claim is in fact a § 1983 [*40] conspiracy claim for violation of Plaintiffs' due process rights. The Court has already found that Plaintiffs have adequately pled a § 1983 due process claim as to Defendants Bobbie Fender, Amber Fender, Schmidt and Smith. See supra § III.B.1. At this early stage of the litigation, the Court finds that Plaintiffs have also adequately pled a § 1983 conspiracy between these Defendants to deprive Plaintiffs of their property on and after August 24, 2008. When read liberally, the Second Amended Complaint discusses each of these four Defendants' conduct so as to sufficiently allege that such conduct occurred by agreement among them. See, e.g., Nelson v. Elway, 908 P.2d 102, 106 (Colo. 1995) (noting that "[t]he court will not infer the agreement necessary to form a conspiracy; evidence of such a conspiracy must be presented by the plaintiff") (emphasis added). As alleged, however, the actions of Defendant Hamby appear to have been unilateral, and the Court therefore finds that this claim should not proceed as to him. Accordingly, the Court recommends that Plaintiff's common law conspiracy claim should be dismissed and that Plaintiff's § 1983 conspiracy claim should be dismissed as to all Defendants [*41] except for Defendants Bobbie Fender, Amber Fender, Schmidt, and Smith. I. No Leave to Amend The dismissal of an action "pursuant to Rule 12(b)(6) is a resolution on the merits and is ordinarily prejudicial." Okusami v. Psychiatric Inst. of Wash., 959 F.2d 1062, 1066, 295 U.S. App. D.C. 58 (D.C. Cir. 1992);accord Brierley v. Schoenfeld, 781 F.2d 838 (10th Cir. 1986) (affirming a district court decision to dismiss with prejudice an action brought under 42 U.S.C. § 1983); Cortec Indus., Inc. v. Sum Holding L.P., 949 F.2d 42, 48 (2nd Cir. 1991) ("where a plaintiff is unable to allege any fact sufficient to support [his] claim, a complaint should be dismissed with prejudice"); Tepper v. Van Dam, 974 F.2d 1345, 1992 WL 219037, at *3-4 (10th Cir. 1992) (relying on Okusami, Brierly, and Cortec to affirm dismissal of an action with prejudice). However, due to heightened concerns when the plaintiff is proceeding pro se, dismissal with prejudice is only appropriate "where it is obvious that the plaintiff cannot prevail on the facts he has alleged and it would be futile to give him an opportunity to amend." Oxendine v. Kaplan, 241 F.3d 1272, 1275 (10th Cir. 2001);see also Brereton v.. Bountiful City Corp., 434 F.3d 1213, 1219 (10th Cir. 2006) [*42] ("A dismissal with prejudice is appropriate where a complaint fails to state a claim under Rule 12(b)(6) and granting leave to amend would be futile.") (citing Grossman v. Novell, Inc., 120 F.3d 1112, 1126 (10th Cir. 1997))). Even as courts are careful to protect the rights of pro se plaintiffs, they often find that granting the opportunity to amend would be futile. See, e. g., Arocho v. Nafziger, 367 F. App'x 942, 955 (10th Cir. 2010) (describing as "unique" circumstances under which giving a plaintiff an opportunity to amend his complaint would not be futile); Reynoldson v. Shillinger, 907 F.2d 124, 127 (10th Cir. 1990) (holding that prejudice should not attach to a dismissal when plaintiff has made allegations "which, upon further investigation and development, could raise substantial issues" (emphasis added)); but see Gee v. Pacheco, 627 F.3d 1178, 1186 (10th Cir. 2010) ("[O]rdinarily the dismissal of a pro se claim under Rule 12(b)(6) should be without prejudice, and a careful judge will explain the pleading's deficiencies so that a prisoner with a meritorious claim can then submit an adequate complaint." (citations omitted)). Plaintiffs have had multiple opportunities since filing [*43] this case in 2010 to present facts to support their purported causes of action. Plaintiffs have had reasonable and ample opportunities to do so, including detailed instructions from both the District Judge and the undersigned explaining the deficiencies of earlier complaints. Plaintiffs have further had the assistance of pro bono legal counsel, which they rejected. Because Plaintiffs 2014 U.S. Dist. LEXIS 42747, *39 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 62 of 106 Page 14 of 14 have failed to assert additional facts in support of their claims, and because they have had multiple opportunities to amend, the Court finds that granting leave to amend again would be futile. Accordingly, the Court recommends that the dismissed causes of action and Defendants, as outlined below, be dismissed with prejudice.See Sheldon v. Vermonty, 269 F.3d 1202, 1207 n.5 (10th Cir. 2001) (stating that dismissal with prejudice is appropriate where the plaintiff's amended pleadings fail to cure the deficiencies in his claims); Meadow at Buena Vista, Inc. v. Ark. Valley Pub. Co., No. 10-cv-02871-MSK-KMT, 2012 U.S. Dist. LEXIS 19234, 2012 WL 502688, at *9 (D .Colo. Feb. 15, 2012) (dismissing causes of action with prejudice where Third Amended Complaint failed to assert additional facts sufficient to support the plaintiff's claims); Stouffer v. Eulberg, No. CIV- 09-320-C, 2009 U.S. Dist. LEXIS 114108, 2009 WL 4724272, at *1 (W.D. Okla. Dec. 7, 2009) [*44] (dismissing cause of action with prejudice where the plaintiff was given the opportunity to amend to correct errors but failed to do so in his amended pleading); Bridges v. Two Unnamed FBI Agents, No. CIV-08-0759-HE, 2009 U.S. Dist. LEXIS 37123, 2009 WL 1227489, at *2 (dismissing causes of action with prejudice where the plaintiff was afforded multiple opportunities to address pleading deficiencies but failed to adequately do so). IV. Recommendation Based on the foregoing, the Court respectfully RECOMMENDS that Motion [#139] be GRANTED in part and DENIED in part and that Motions [#151, #176, #190] be GRANTED. Accordingly, the Court recommends that all claims against Defendants Schirard, Bobbie Fender, Amber Fender, Schmidt, Hamby, Smith, Harrington, Webb, Phippen, Williams, Burke, Lieb, Lachelt, Westendor, Kosnik, Tebrink, Hutchins, Graeber, and the past and present Board of County Commissioners of La Plata County be dismissed with prejudice except for the following: Claim 1 (§ 1983 due process claim) against Defendants Bobbie Fender, Amber Fender, Schmidt, Hamby, and Smith; and Claim 7 (§ 1983 conspiracy) against Defendants Bobbie Fender, [*45] Amber Fender, Schmidt, and Smith. IT IS HEREBY ORDERED that pursuant to Fed. R. Civ. P. 72, the parties shall have fourteen (14) days after service of this Recommendation to serve and file any written objections in order to obtain reconsideration by the District Judge to whom this case is assigned. A party's failure to serve and file specific, written objections waives de novo review of the Recommendation by the District Judge, Fed. R. Civ. P. 72(b);Thomas v. Arn, 474 U.S. 140, 147-48, 106 S. Ct. 466, 88 L. Ed. 2d 435 (1985), and also waives appellate review of both factual and legal questions. Makin v. Colo. Dep't of Corr., 183 F.3d 1205, 1210 (10th Cir. 1999);Talley v. Hesse, 91 F.3d 1411, 1412-13 (10th Cir. 1996). A party's objections to this Recommendation must be both timely and specific to preserve an issue for de novo review by the District Court or for appellate review. United States v. One Parcel of Real Prop., 73 F.3d 1057, 1060 (10th Cir. 1996). Dated: February 11, 2014 BY THE COURT: /s/ Kristen L. Mix Kristen L. Mix United States Magistrate Judge End of Document 2014 U.S. Dist. LEXIS 42747, *43 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 63 of 106 Positive As of: October 8, 2021 1:56 AM Z Scherer v. City of Merriam United States District Court for the District of Kansas May 10, 2002, Decided CIVIL ACTION No. 01-2092-KHV Reporter 2002 U.S. Dist. LEXIS 9530 * THOMAS E. SCHERER, Plaintiff, v. CITY OF MERRIAM, Defendant. Disposition: Defendant's motion to dismiss sustained, but plaintiff's granted leave to amend complaint. Core Terms motion to dismiss, allegations, campaign, sign ordinance, due process, municipal, failure to state a claim, conscience, pleadings, shock, constitutional right, motion for judgment, equal protection, right of way, misinterpreted, construes, custom, due process claim, ordinance Case Summary Procedural Posture Defendant, a city and other officials, filed a motion to dismiss plaintiff's, a former political candidate, complaint in which it was alleged that the city violated the former candidate's right to equal protection by removing a political campaign sign from a municipal right of way and failing to later to investigate the incident. Overview The court construed the city's motion to dismiss as a motion for judgment on the pleadings. The city sought to dismiss the complaint for failure to state a claim on which relief could be granted. The court held that the city could not be liable for the acts of its employees and agents under 42 U.S.C.S. § 1983 on a theory of vicarious liability or respondeat superior. The city could be liable under § 1983 only if an official custom or policy of the city caused a violation of the former candidate's constitutional, or an individual with final policymaking authority made the decision which violated his constitutional rights. The court held that the complaint did not identify any municipal custom or policy or decision by an individual with final policymaking authority. The complaint did not link any alleged custom, policy, or decision to a violation of his constitutional rights. However, the court granted leave to amend to allow the former candidate to add factual allegations to support a claim that the city officials misinterpreted the sign ordinance pursuant to municipal custom or policy and/or the sign ordinance, either on its face or as applied, was unconstitutional. Outcome The court sustained the city's motion for judgment on the pleadings, but granted the former candidate leave to amend his complaint. LexisNexis® Headnotes Civil Procedure > Dismissal > Involuntary Dismissals > Failure to State Claims Civil Procedure > ... > Defenses, Demurrers & Objections > Motions to Dismiss > Failure to State Claim Civil Procedure > ... > Responses > Defenses, Demurrers & Objections > Motions to Dismiss Civil Procedure > Pleading & Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 64 of 106 Page 2 of 8 Practice > Pleadings > Rule Application & Interpretation Civil Procedure > Judgments > Pretrial Judgments > General Overview Civil Procedure > Judgments > Pretrial Judgments > Judgment on Pleadings HN1[] Involuntary Dismissals, Failure to State Claims A motion to dismiss for failure to state a claim filed after an answer is construed as a Fed. R. Civ. P. 12(c) motion for judgment on the pleadings but the governing standards are identical. A Rule 12(b)(6) motion should not be granted unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief. The court accepts all well-pleaded factual allegations in the complaint as true and draws all reasonable inferences from those facts in favor of plaintiff. The issue in reviewing the sufficiency of plaintiff's complaint is not whether plaintiff will prevail, but whether plaintiff is entitled to offer evidence to support his claims. Although plaintiff need not precisely state each element of his claims, he must plead minimal factual allegations on those material elements that must be proved. Civil Procedure > Parties > Pro Se Litigants > Pleading Standards Civil Procedure > Pleading & Practice > Pleadings > Rule Application & Interpretation Civil Procedure > Parties > Pro Se Litigants > General Overview HN2[] Pro Se Litigants, Pleading Standards The court affords a pro se plaintiff some leniency and must liberally construe the complaint. While pro se complaints are held to less stringent standards than pleadings drafted by lawyers, pro se litigants must follow the same procedural rules as other litigants. The court may not assume the role of advocate for a pro se litigant. Civil Procedure > ... > Defenses, Demurrers & Objections > Motions to Dismiss > Failure to State Claim Civil Procedure > Pleading & Practice > Pleadings > Rule Application & Interpretation Civil Procedure > Dismissal > Involuntary Dismissals > Failure to State Claims Civil Procedure > Judgments > Pretrial Judgments > General Overview Civil Procedure > Judgments > Pretrial Judgments > Judgment on Pleadings Civil Procedure > Judgments > Preclusion of Judgments > Res Judicata HN3[] Motions to Dismiss, Failure to State Claim Pursuant to Fed. R. Civ. P. 12(h)(2), a defense of failure to state a claim may be made in any pleading permitted or ordered under Fed. R. Civ. P. 7(a), or by motion for judgment on the pleadings, or at the trial on the merits. Rule 12 does not prohibit a defendant from filing multiple motions for judgment on the pleadings based on different issues. Civil Rights Law > ... > Section 1983 Actions > Scope > Government Actions Governments > Local Governments > Claims By & Against Civil Rights Law > ... > Immunity From Liability > Local Officials > General Overview Civil Rights Law > Protection of Rights > Immunity From Liability > Respondeat Superior Distinguished Civil Rights Law > Protection of Rights > Section 1983 Actions > Scope 2002 U.S. Dist. LEXIS 9530, *9530 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 65 of 106 Page 3 of 8 Torts > ... > Employers > Activities & Conditions > General Overview HN4[] Scope, Government Actions A city cannot be liable for the acts of its employees and agents under 42 U.S.C.S. § 1983 on a theory of vicarious liability or respondeat superior. The city can be liable under § 1983 only if an official custom or policy of the city caused a violation of plaintiff's constitutional rights, or an individual with final policymaking authority made the decision which violated his constitutional rights. Constitutional Law > Equal Protection > Nature & Scope of Protection HN5[] Equal Protection, Nature & Scope of Protection Unless a plaintiff alleges a violation of a fundamental right or discrimination against a suspect class, a defendant only needs a rational justification for differential treatment. Constitutional Law > ... > Fundamental Freedoms > Freedom of Religion > Free Exercise of Religion Constitutional Law > ... > Fundamental Freedoms > Freedom of Religion > General Overview Constitutional Law > Equal Protection > General Overview Constitutional Law > Equal Protection > Nature & Scope of Protection HN6[] Freedom of Religion, Free Exercise of Religion In general, provided that an ordinance is rationally based, the failure to enforce it with complete equality does not of itself infringe the constitutional principle of equal protection. Mere failure to prosecute other offenders is no basis for a finding of denial of equal protection. Constitutional Law > ... > Fundamental Rights > Procedural Due Process > General Overview Constitutional Law > Substantive Due Process > General Overview Constitutional Law > Substantive Due Process > Scope HN7[] Fundamental Rights, Procedural Due Process The touchstone of due process is protection of the individual against arbitrary action of government, including the exercise of power without any reasonable justification in the service of a legitimate governmental objective. In cases of abusive executive action, only the most egregious official conduct can be said to be arbitrary in the constitutional sense. The standard for judging a substantive due process claim is whether the challenged government action would shock the conscience of federal judges. To satisfy this standard, a plaintiff must do more than show that the government actor intentionally or recklessly caused injury to the plaintiff by abusing or misusing government power. Instead, a plaintiff must demonstrate a degree of outrageousness and a magnitude of potential or actual harm that is truly conscience shocking. Generally conscience shocking behavior falls on the far side of the culpability spectrum, requiring the plaintiff to show that the government actor performed with an intent to harm. Where the state actor has the luxury to truly deliberate about the decisions he or she is making, something less than unjustifiable intent to harm, such as calculated indifference, may suffice to shock the conscience. Counsel: [*1] THOMAS E SCHERER, plaintiff, Pro se, Merriam, KS. For MERRIAM, KANSAS, CITY OF, defendant: Jeffrey A. Bullins, Holbrook, Heaven & Osborn P.A., Kansas City, KS. For MERRIAM, KANSAS, CITY OF, defendant: Lewis A. Heaven, Jr., Richard J. Plouff, Holbrook, 2002 U.S. Dist. LEXIS 9530, *9530 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 66 of 106 Page 4 of 8 Heaven & Osborn, P.A., Merriam, KS. Judges: KATHRYN H. VRATIL, United States District Judge. Opinion by: KATHRYN H. VRATIL Opinion MEMORANDUM AND ORDER Plaintiff, a former candidate for political office, filed suit against the City of Merriam, Kansas and various other officials, alleging that they violated his right to equal protection by removing a political campaign sign from a municipal right of way and failing to later investigate the incident. This matter is before the Court on the City Of Merriam's Motion To Dismiss (Doc. # 64), which the Court reinstated on April 10, 2002 and construes as a motion for judgment on the pleadings pursuant to Rule 12(c), Fed. R. Civ. P.1 For reasons stated below, the Court sustains the City's motion but grants plaintiff leave to amend. [*2] Factual Background Plaintiff's complaint alleges the following facts: Plaintiff was a candidate for political office. On February 21, 2001, the City of Merriam removed one of plaintiff's campaign signs because it was in the city "right of way," i.e. the area immediately adjacent to the street. 2 The City removed plaintiff's 1 See Jacobsen v. Deseret Book Co., 287 F.3d 936, 2002 U.S. App. LEXIS 7351 at * 14 n.2 (10th Cir. April 19, 2002) (if defendant makes motion to dismiss for failure to state a claim after filing answer, motion should generally be treated as motion for judgment on the pleadings under Rule 12(c)). 2 In a separate action filed with the Kansas Board of Tax Appeals, plaintiff claims that the City does not have a right of way on the particular parcel of residential property where plaintiff's sign was located. sign pursuant to a city sign ordinance, but it did not remove similarly situated campaign signs. On February 22, 2001, plaintiff attempted to complain to the Merriam Police Department, the Johnson County Kansas Election Board ("JCEB"), Paul Morrison (District Attorney of Johnson County) and Carla Stovall (Attorney General for the State of Kansas). Each of the agencies and individuals "failed to take a report and protect Mr. Scherer's property rights. [*3] " Civil Complaint (Doc. # 1) filed February 23, 2001 at 3. Procedural Background On February 23, 2001, plaintiff filed suit against the City of Merriam, the Johnson County Kansas Election Board ("JCEB"), Connie Schmidt (Johnson County Election Commissioner), Paul Morrison (District Attorney of Johnson County) and Carla Stovall (Attorney General for the State of Kansas). Plaintiff alleges that (1) his campaign sign should not have been removed pursuant to the City's sign ordinance because the City did not have a "right of way" on the particular parcel of property and (2) even if the City had a "right of way" on the property, his campaign sign did not violate the ordinance because it was more than six feet from the curb or one foot from the sidewalk. Liberally construing the complaint, plaintiff alleges that defendants violated his constitutional rights to equal protection, due process and free speech. On June 29, 2001, the Court sustained the motion to dismiss of JCEB and Schmidt, on account of insufficient service of process and failure to state a claim.See Memorandum And Order (Doc. # 38) at 4-7. In the same order, the Court sustained the motion to dismiss [*4] of Stovall and Morrison, on account of sovereign immunity and absolute prosecutorial immunity. See id. at 8-9. On September 5, 2001, the Court overruled plaintiff's motion to reconsider its order of dismissal. See Memorandum And Order (Doc. # 57). The Court also sustained the City of Merriam's motion to dismiss, on account of insufficient service of process, but allowed plaintiff to re-serve the City by October 12, 2001. See id. at 5. 2002 U.S. Dist. LEXIS 9530, *1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 67 of 106 Page 5 of 8 On September 13, 2001, plaintiff filed a notice of appeal of the order of September 5. On September 21, 2001, plaintiff notified the Court that he had served the City of Merriam as required by the order from which he had appealed. On October 2, 2001, the City of Merriam filed a motion to dismiss for failure to state a claim. See Motion To Dismiss (Doc. # 64). On January 14, 2002, the Court directed the Clerk to administratively terminate the City's motion to dismiss pending a ruling by the Tenth Circuit Court of Appeals. See Order (Doc. # 79). After the Tenth Circuit dismissed plaintiff's appeal for lack of jurisdiction, the Court reinstated the City's motion to dismiss. See Order (Doc. # 83) filed April 10, 2002. Standards [*5] For Motion To Dismiss For Failure To State A Claim HN1[]A motion to dismiss for failure to state a claim filed after an answer is construed as a Rule 12(c) motion for judgment on the pleadings but the governing standards are identical. See Jacobsen,287 F.3d 936, 2002 WL 652250,at * 14 n.2. A Rule 12(b)(6) motion should not be granted unless "it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief." GFF Corp. v. Assoc. Wholesale Grocers., Inc., 130 F.3d 1381, 1384 (10th Cir. 1997) (quoting Conley v. Gibson, 355 U.S. 41, 45-46, 2 L. Ed. 2d 80, 78 S. Ct. 99 (1957)). The Court accepts all well- pleaded factual allegations in the complaint as true and draws all reasonable inferences from those facts in favor of plaintiff. See Shaw v. Valdez, 819 F.2d 965, 968 (10th Cir. 1987). The issue in reviewing the sufficiency of plaintiff's complaint is not whether plaintiff will prevail, but whether plaintiff is entitled to offer evidence to support his claims.See Scheuer v. Rhodes, 416 U.S. 232, 236, 40 L. Ed. 2d 90, 94 S. Ct. 1683, 71 Ohio Op. 2d 474 (1974).Although [*6] plaintiff need not precisely state each element of his claims, he must plead minimal factual allegations on those material elements that must be proved. See Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). HN2[] The Court affords a pro se plaintiff some leniency and must liberally construe the complaint. See Oltremari v. Kan. Soc. & Rehab. Servs., 871 F. Supp. 1331, 1333 (D. Kan. 1994). While pro se complaints are held to less stringent standards than pleadings drafted by lawyers, pro se litigants must follow the same procedural rules as other litigants. See Hughes v. Rowe, 449 U.S. 5, 9, 66 L. Ed. 2d 163, 101 S. Ct. 173 (1980); Green v. Dorrell, 969 F.2d 915, 917 (10th Cir. 1992).The Court may not assume the role of advocate for a pro se litigant. See Hall, 935 F.2d at 1110. Analysis The City of Merriam asks the Court to dismiss plaintiff's claims for failure to state a claim on which relief may be granted. The substance of the City's motion is essentially uncontested. Plaintiff argues only that the City is barred from filing a second motion to dismiss under "res judicata-issue [*7] preclusion" principles. See plaintiff's Reply To The City Of Merriam's Motion To Dismiss (Doc. # 67) filed October 10, 2001 at 1. The Court disagrees. The City's first motion to dismiss, 3 which the Court sustained, was based solely on plaintiff's failure to properly serve the City. Because the City's first motion to dismiss did not involve a challenge to the sufficiency of plaintiff's complaint, res judicata principles do not bar the instant motion. Moreover, HN3[] pursuant to Rule 12(h)(2), a defense of failure to state a claim "may be made in any pleading permitted or ordered under Rule 7(a), or by motion for judgment on the pleadings, or at the trial on the merits." Rule 12 does not prohibit a defendant from filing multiple motions for judgment on the pleadings based on different issues. In this case, because the City has already filed an answer, the Court construes the City's motion to dismiss for failure to state a claim as a Rule 12(c) motion for judgment on the pleadings. See Jacobsen, 287 F.3d 936, 2002 WL 652250, at * 14 n.2. 3 The Court previously noted that the City's first motion to dismiss was actually a motion for judgment on the pleadings pursuant to Rule 12(c), Fed. R. Civ. P.See Memorandum And Order (Doc. # 38) at 4 n.3. 2002 U.S. Dist. LEXIS 9530, *4 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 68 of 106 Page 6 of 8 [*8] HN4[] I. Municipal Liability The City argues that plaintiff has failed to state a claim for several alternative reasons, but the City's status as a municipality is dispositive. The City cannot be liable for the acts of its employees and agents under Section 1983 on a theory of vicarious liability or respondeat superior. See Monell v. Dep't Of Social Servs., 436 U.S. 658, 692, 56 L. Ed. 2d 611, 98 S. Ct. 2018 (1978);Sauers v. Salt Lake County, 1 F.3d 1122, 1129 (10th Cir. 1993). The City can be liable under Section 1983 only if an official custom or policy of the City caused a violation of plaintiff's constitutional rights, see Monell, 436 U.S. at 694; Kentucky v. Graham, 473 U.S. 159, 165-66, 87 L. Ed. 2d 114, 105 S. Ct. 3099 (1985), or an individual with final policymaking authority made the decision which violated his constitutional rights, see Pembaur v. City Of Cincinnati, 475 U.S. 469, 481-84, 89 L. Ed. 2d 452, 106 S. Ct. 1292 (1986) (holding that single decision by official responsible for establishing final policy may give rise to municipal liability); Jantz v. Muci, 976 F.2d 623, 630 (10th Cir. 1992) [*9] (same),cert. denied,508 U.S. 952, 124 L. Ed. 2d 662, 113 S. Ct. 2445 (1993).4 With respect to all of plaintiff's claims, the complaint does not identify any municipal custom or policy or decision by an individual with final policymaking authority. Indeed, plaintiff's claims are based primarily on the failure of City officials to follow the sign ordinance [*10] with respect to one of plaintiff's signs - the virtual antithesis of a "custom or practice." In addition, the complaint does not link any alleged custom, policy or 4 Plaintiff does not allege any failure to train by the City. Even if he did so, a municipality can be held liable only when its failure to train reflects a "deliberate or conscious choice" to ignore serious risks to a person's health and safety. City of Canton v. Harris, 489 U.S. 378, 388-89, 103 L. Ed. 2d 412, 109 S. Ct. 1197 (1989);see Myers v. Okla. County Bd. of County Commr's, 151 F.3d 1313, 1318 (10th Cir. 1998). Plaintiff has not alleged that (1) the City made a deliberate or conscious choice not to train or supervise its employees or (2) the City ignored serious risks to health and safety. decision to a violation of plaintiff's constitutional rights. The Court therefore sustains the City's motion to dismiss. Because plaintiff may be able to correct this pleading deficiency with respect to at least one of his claims, however, the Court briefly analyzes the merits of each claim. II. Equal Protection / Selective Enforcement Plaintiff alleges that the City of Merriam denied him equal protection of the law when it (1) took his campaign sign while leaving similarly situated signs and (2) failed to take a police report on the incident. As the Court previously noted, HN5[] unless plaintiff alleges a violation of a fundamental right or discrimination against a suspect class, defendant only needs a rational justification for differential treatment. See Memorandum And Order (Doc. # 38) filed June 29, 2001 at 7 (citing Penrod v. Zavaras, 94 F.3d 1399, 1406 (10th Cir. 1996)). Plaintiff does not allege the violation of a fundamental right nor does he allege status in a protected class. The [*11] City therefore needs only a rational basis for its actions. Plaintiff's complaint does not allege the lack of a rational basis.5 To the extent plaintiff alleges that City engaged in selective enforcement of [*12] the sign ordinance, he has not stated a claim because he has not alleged that the City singled him out by use of impermissible considerations "such as race, religion, or the desire to prevent the exercise of a constitutional right." Bryan v. City Of Madison, Miss., 213 F.3d 267, 277 (5th Cir. 2000);see 5 With respect to plaintiff's claim that the City Police Department did not take a report, plaintiff also does not allege any differential treatment by the City and he therefore fails to plead the material elements of an equal protection claim. See Hall, 935 F.2d at 1110;Tonkovich v. Kansas Bd. of Regents, 159 F.3d 504, 533 (10th Cir. 1998) ("At the heart of any equal protection claim must be an allegation of being treated differently than those similarly situated."); see also Village Of Willowbrook v. Olech, 528 U.S. 562, 564, 145 L. Ed. 2d 1060, 120 S. Ct. 1073 (2000) ("class of one" must show that he has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment). 2002 U.S. Dist. LEXIS 9530, *7 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 69 of 106 Page 7 of 8 Harlen Assocs. v. Inc. Village of Mineola, 273 F.3d 494, 499 (2d Cir. 2001).HN6[] In general, provided that an ordinance is rationally based, the failure to enforce it "with complete equality does not of itself infringe the constitutional principle of equal protection." D'Acquisto v. Washington, 640 F. Supp. 594, 625 (N.D. Ill. 1986). "Mere failure to prosecute other offenders is no basis for a finding of denial of equal protection." Cook v. City Of Price, Carbon County, Utah, 566 F.2d 699, 701 (10th Cir. 1977);see Oyler v. Boles, 368 U.S. 448, 456, 7 L. Ed. 2d 446, 82 S. Ct. 501 (1962) ("The conscious exercise of some selectivity in enforcement is not in itself a federal constitutional violation"). For these reasons, plaintiff has failed to state a claim for violation of his rights to equal protection. [*13] III. Due Process Plaintiff claims that the City's actions violated his due process rights. He does not specify whether his claim is based on procedural or substantive due process, so the Court will analyze his claim under both potential theories. A.Procedural Due Process Plaintiff's complaint is too vague and conclusory to state a claim for violation of his constitutional right to procedural due process. Plaintiff has a property interest in his own campaign sign, but he does not set forth any specific federal or constitutional procedural safeguards that the City allegedly violated. See Tonkovich, 159 F.3d at 519-20 (procedural due process claim must set forth procedures due under law). Plaintiff may be able to state a procedural due process claim based on the manner in which City officials removed his sign, but at this point, plaintiff's complaint only alleges that the City removed the sign in violation of his right to due process. Such conclusory allegations are insufficient to state a claim on which relief can be granted. See Hall, 935 F.2d at 1110 (pro se plaintiff must allege sufficient facts on which a recognized [*14] legal claim could be based; conclusory allegations without supporting factual averments are insufficient). The Court therefore sustains the City's motion to dismiss as to plaintiff's procedural due process claim but grants plaintiff leave to file an amended complaint on or before May 28, 2002. B.Substantive Due Process Plaintiff apparently attempts to assert a claim for violation of his substantive due process rights based on the City's removal of his campaign sign. "HN7[] The touchstone of due process is protection of the individual against arbitrary action of government," Wolff v. McDonnell, 418 U.S. 539, 558, 41 L. Ed. 2d 935, 94 S. Ct. 2963, 71 Ohio Op. 2d 336 (1974), including the exercise of power without any reasonable justification in the service of a legitimate governmental objective, see, e.g., Daniels v. Williams, 474 U.S. 327, 331, 88 L. Ed. 2d 662, 106 S. Ct. 662 (1986) (substantive due process protects against government power arbitrarily and oppressively exercised); County Of Sacramento v. Lewis, 523 U.S. 833, 846, 140 L. Ed. 2d 1043, 118 S. Ct. 1708 (1998). In cases of "abusive executive action," only the most egregious [*15] official conduct can be said to be "arbitrary in the constitutional sense." 523 U.S. at 849 (citing Collins v. City Of Harker Heights, 503 U.S. 115, 129, 117 L. Ed. 2d 261, 112 S. Ct. 1061 (1992)). "The standard for judging a substantive due process claim is whether the challenged government action would 'shock the conscience of federal judges.'" Tonkovich, 159 F.3d at 528 (quoting Uhlrig v. Harder, 64 F.3d 567, 573 (10th Cir. 1995),cert. denied,516 U.S. 1118, 133 L. Ed. 2d 853, 116 S. Ct. 924 (1996)). To satisfy this standard, "a plaintiff must do more than show that the government actor intentionally or recklessly caused injury to the plaintiff by abusing or misusing government power." 64 F.3d at 574. Instead, a plaintiff "must demonstrate a degree of outrageousness and a magnitude of potential or actual harm that is truly conscience shocking." Id. Generally conscience shocking behavior falls on the far side of the culpability spectrum, requiring the plaintiff to show that the government actor performed with an intent to harm. In Radecki v. Barela, 146 F.3d 1227 (10th Cir. 1998), [*16] cert. denied,525 U.S. 1103, 142 L. Ed. 2d 771, 119 S. 2002 U.S. Dist. LEXIS 9530, *12 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 70 of 106 Page 8 of 8 Ct. 869 (1999), the Tenth Circuit expanded this narrow reading. There, the court held that "where the state actor has the luxury to truly deliberate about the decisions he or she is making, something less than unjustifiable intent to harm, such as calculated indifference, may suffice to shock the conscience." 146 F.3d at 1232. The Court finds that removal of a single political campaign sign, even if the sign is technically on private property, does not "shock the conscience." At most, plaintiff has alleged that unidentified City officials misinterpreted or did not understand the municipal sign ordinance, certainly not conduct which can be considered as abusive or outrageous. Cf.Rochin v. California, 342 U.S. 165, 96 L. Ed. 183, 72 S. Ct. 205 (1952) (an invasion of one's body, such as pumping a suspect's stomach, will "shock the conscience"). Because the alleged conduct of the unidentified City officials is not so egregious as to "shock the conscience," the City's motion to dismiss plaintiff's substantive due process claim is sustained. IV.First Amendment / Free Speech [*17] Liberally construing plaintiff's complaint, plaintiff alleges that the City violated his First Amendment rights by removing his campaign sign. Plaintiff essentially claims that (1) his campaign sign should not have been removed pursuant to the City's sign ordinance because the City did not have a "right of way" on the particular parcel of property and (2) even if the City had a "right of way" on the property, his campaign sign did not violate the ordinance because it was more than six feet from the curb or one foot from the sidewalk. At the heart of both claims is an allegation that a City official misinterpreted or misunderstood the sign ordinance. 6 Such an allegation, by itself, is insufficient to state a claim against a municipality. Plaintiff has not alleged that City official(s) misinterpreted the sign ordinance pursuant to a 6 The Court does not construe plaintiff's complaint as a challenge to the sign ordinance itself. To the extent plaintiff desires to raise such a challenge, he may file an amended complaint on or before May 28, 2002. municipal custom or policy or that an individual with final policymaking authority misinterpreted the ordinance. See Hall, 935 F.2d at 1110 (pro se plaintiff must allege sufficient facts on which a recognized legal claim could be based; conclusory allegations without supporting factual averments are insufficient to state a claim on [*18] which relief can be based). Accordingly, the Court sustains the City's motion to dismiss but grants plaintiff leave to file an amended complaint which adds factual allegations to support a claim that (1) City officials misinterpreted the sign ordinance pursuant to a municipal custom or policy or that an individual with final policymaking authority misinterpreted the ordinance and/or (2) the City's sign ordinance, either on its face or as applied, is unconstitutional. 7 See id. (plaintiff whose factual allegations are close to stating a claim but are missing some important element that may not have occurred to him, should be allowed to amend complaint). [*19] IT IS THEREFORE ORDERED that the City Of Merriam's Motion To Dismiss (Doc. # 64), which the Court reinstated on April 10, 2002 and construes as a motion for judgment on the pleadings pursuant to Rule 12(c), Fed. R. Civ. P., be and hereby is SUSTAINED. On or before May 28, 2002, plaintiff may file an amended complaint. Dated this 10th day of May, 2002 at Kansas City, Kansas. KATHRYN H. VRATIL United States District Judge End of Document 7 It is not readily apparent that plaintiff can cure the pleading deficiencies identified above with respect to his equal protection and due process claims. To the extent plaintiff believes that those claims can be saved by amendment, he may also include them in his amended complaint to be filed on or before May 28, 2002. 2002 U.S. Dist. LEXIS 9530, *16 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 71 of 106 Neutral As of: October 8, 2021 1:57 AM Z Trujillo v. Campbell United States District Court for the District of Colorado August 22, 2012, Decided; August 22, 2012, Filed Civil Action No. 09-cv-03011-CMA-KLM Reporter 2012 U.S. Dist. LEXIS 118585 *; 2012 WL 3609747 VICKI LYNN TRUJILLO, individually and on behalf of the Estate of Jason Gomez, Plaintiff, v. TIMOTHY CAMPBELL, individually and as a Police Officer of the City and County of Denver, GERALD R. WHITMAN, individually and in his official capacity as Chief of Police of the City and County of Denver, and THE CITY AND COUNTY OF DENVER, a municipal corporation, Defendants. Subsequent History: Motion denied by, Motion denied by, As moot, Stay denied by, As moot Trujillo v. Campbell, 2012 U.S. Dist. LEXIS 145761 (D. Colo., Oct. 10, 2012) Prior History:Trujillo v. Campbell, 2012 U.S. Dist. LEXIS 70154 (D. Colo., May 21, 2012) Core Terms excessive force, complaints, municipal, conspiracy, municipal liability, training, police officer, discipline, summary judgment, custom, summary judgment motion, investigate, shooting, genuine, rights, qualified immunity, material fact, causal link, deliberately, flee, deliberate indifference, statistical evidence, use of force, shot, constitutional right, light most favorable, police department, failure to train, use deadly force, triable issue Case Summary Overview HOLDINGS: [1]-In an action pursuant to the Fourth Amendment, defendants were not entitled to qualified immunity and judgment was not appropriate as a matter of law because defendant police officer violated plaintiff's clearly established rights as all three of the Graham case law factors weighed heavily in plaintiff's favor; [2]-In an action for municipality liability under 42 U.S.C.S. § 1983, defendants were entitled to summary judgment because plaintiff could not survive summary judgment on her failure to train claim as she had provided no evidence of deliberate indifference on the part of defendant with respect to the training materials; [3]-Defendants were entitled to summary judgment under 42 U.S.C.S. § 1985(3) because plaintiff's evidence of § 1985(3) conspiracy was inadequate as she had offered no evidence that a conspiracy existed. Outcome Motion granted in part and denied in part. Claims dismissed with prejudice. LexisNexis® Headnotes Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Genuine Disputes Civil Procedure > ... > Summary Judgment > Burdens of Proof > Movant Persuasion & Proof Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Materiality of Facts HN1[] Entitlement as Matter of Law, Genuine Disputes Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 72 of 106 Page 2 of 14 Summary judgment is appropriate if the moving party demonstrates that there is no genuine dispute as to any material fact and that it is entitled to a judgment as a matter of law. Fed. R. Civ. P. 56(a). In applying this standard, the district court views the evidence and all reasonable inferences therefrom in the light most favorable to the nonmoving party. A fact is "material" if, under the applicable substantive law, it is essential to the proper disposition of the claim. A dispute of fact is "genuine" if there is sufficient evidence on each side so that a rational trier of fact could resolve the issue either way. Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Genuine Disputes Civil Procedure > ... > Summary Judgment > Burdens of Proof > Movant Persuasion & Proof Civil Procedure > ... > Summary Judgment > Entitlement as Matter of Law > Materiality of Facts Civil Procedure > ... > Summary Judgment > Burdens of Proof > Nonmovant Persuasion & Proof HN2[] Entitlement as Matter of Law, Genuine Disputes For purposes of a motion for summary judgment, the moving party bears the initial burden of demonstrating an absence of a genuine issue of material fact and entitlement to judgment as a matter of law. In attempting to meet that standard, a movant who does not bear the ultimate burden of persuasion at trial does not need to disprove the other party's claim; rather, the movant need simply point out to the court a lack of evidence for the other party on an essential element of that party's claim. Once the movant has met this initial burden, the burden shifts to the nonmoving party to set forth specific facts showing that there is a genuine issue for trial. The nonmoving party may not simply rest upon its pleadings to satisfy its burden. Rather, the nonmoving party must set forth specific facts that would be admissible in evidence in the event of trial from which a rational trier of fact could find for the nonmovant. To accomplish this, the facts must be identified by reference to affidavits, deposition transcripts, or specific exhibits incorporated therein. Civil Rights Law > Protection of Rights > Immunity From Liability Evidence > Burdens of Proof > Burden Shifting HN3[] Protection of Rights, Immunity From Liability Under the doctrine of qualified immunity, government officials are protected from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known. Qualified immunity requires a two-step sequence. When a defendant asserts qualified immunity at summary judgment, the burden shifts to a plaintiff to show that: (1) the defendant violated a constitutional right and (2) the constitutional right was clearly established. Only if a plaintiff can satisfy both steps will the assertion of qualified immunity be defeated. Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection Criminal Law & Procedure > Commencement of Criminal Proceedings > Arrests > Reasonable Force HN4[] Search & Seizure, Scope of Protection Claims of excessive force are analyzed under the objective reasonableness standard of the Fourth Amendment. In determining whether the use of force was reasonable, the district court must pay careful attention to the facts and circumstances in this particular situation, including the severity of the crime at issue, whether the suspect poses an 2012 U.S. Dist. LEXIS 118585, *118585 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 73 of 106 Page 3 of 14 immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight. Under this objective standard, the question is whether an officer's actions were objectively reasonable in light of the facts and circumstances confronting him, without regard to his underlying intent or motivation. In determining whether the use of force was reasonable, the Court must pay careful attention to the facts and circumstances in a particular situation, including the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight. Constitutional Law > Bill of Rights > Fundamental Rights > Search & Seizure HN5[] Fundamental Rights, Search & Seizure For purposes of Fourth Amendment rights, no reasonable officer would have reason to believe that a fleeing person not suspected of any specific crime and who had not made any threatening gestures posed any danger. Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection Criminal Law & Procedure > Commencement of Criminal Proceedings > Arrests > Reasonable Force Criminal Law & Procedure > Search & Seizure > Seizure of Persons HN6[] Search & Seizure, Scope of Protection In the contexts of Fourth Amendment rights to be free form unlawful seizure through the use of deadly force, the reasonableness of an officer's conduct may depend on whether the officer's own deliberate or reckless conduct created the need to use deadly force. Civil Rights Law > Protection of Rights > Immunity From Liability > Local Officials Criminal Law & Procedure > Commencement of Criminal Proceedings > Arrests > Reasonable Force Criminal Law & Procedure > Search & Seizure > Seizure of Persons HN7[] Immunity From Liability, Local Officials In the context of doctrine of qualified immunity, the relevant, dispositive inquiry in determining whether a right is clearly established is whether it would be clear to a reasonable officer that his conduct was unlawful in the situation he confronted. The question of whether a right is clearly established must be addressed in light of the specific context of the case. Where the suspect poses no immediate threat to the officer and no threat to others, the harm resulting from failing to apprehend him does not justify the use of deadly force to do so. In other words, a police officer may not seize an unarmed, nondangerous suspect by shooting him dead. A police officer may not use deadly force to seize an unarmed and nondangerous suspect who flees from a police officer. Civil Rights Law > Protection of Rights > Section 1983 Actions > Scope Governments > Local Governments > Claims By & Against Evidence > Burdens of Proof > Allocation HN8[] Protection of Rights, Section 1983 Actions A municipality may not be held liable under 42 U.S.C.S. § 1983 merely on the basis of its status as an employer. Rather, to establish municipal liability, a plaintiff must demonstrate two elements: (1) a municipal employee committed a 2012 U.S. Dist. LEXIS 118585, *118585 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 74 of 106 Page 4 of 14 constitutional violation; and (2) a direct causal link between the injury alleged and a municipal policy or custom. Civil Rights Law > ... > Immunity From Liability > Local Officials > Direct Causal Links Evidence > Burdens of Proof > Allocation Governments > Local Governments > Claims By & Against Civil Rights Law > ... > Section 1983 Actions > Scope > Law Enforcement Officials HN9[] Local Officials, Direct Causal Links To establish a claim for a municipality's failure to train its police officers, a plaintiff must first prove that the training was, in fact, inadequate. If a plaintiff can do so, she must then satisfy the following requirements:(1) the officers exceeded constitutional limitations on the use of force; (2) the use of force arose under circumstances that constitute a usual and recurring situation with which police officers must deal; (3) the inadequate training demonstrates a deliberate indifference on the part of the city toward persons with whom the police officers come into contact, and (4) there is a direct causal link between the constitutional deprivation and the inadequate training. Evidence > Burdens of Proof > Allocation Governments > Local Governments > Claims By & Against HN10[] Burdens of Proof, Allocation To show deliberate indifference, a plaintiff must present facts showing that the municipality has actual or constructive notice that its action or failure to act is substantially certain to result in a constitutional violation, and it consciously or deliberately chooses to disregard the risk of harm. In the specific context of inadequate training, deliberate indifference is shown when the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, that the policymakers of the city can reasonably be said to have been deliberately indifferent to the need. Civil Rights Law > ... > Section 1983 Actions > Scope > Law Enforcement Officials Evidence > Burdens of Proof > Allocation Governments > Local Governments > Claims By & Against HN11[] Scope, Law Enforcement Officials In the context of a municipality's failure to train its police officers claim, a plaintiff must show genuine disputes of material fact that a defendant has in place (1) a custom or policy of failure to discipline; (2) deliberate indifference on the part of a policy maker, and (3) a causal link to the constitutional deprivation. Civil Rights Law > ... > Section 1983 Actions > Elements > Causal Relationship Governments > Local Governments > Claims By & Against Evidence > Burdens of Proof > Allocation HN12[] Elements, Causal Relationship To prevail on a 42 U.S.C.S. § 1983 municipal liability claim, a plaintiff must show a causal link between the policy and constitutional deprivation. Civil Rights Law > ... > Section 1983 Actions > Scope > Law Enforcement Officials Governments > Local Governments > Claims By & Against Evidence > Burdens of Proof > Allocation HN13[] Scope, Law Enforcement Officials 2012 U.S. Dist. LEXIS 118585, *118585 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 75 of 106 Page 5 of 14 In the context of a municipality's failure to supervise its police officers claim, a municipality may be held liable where a plaintiff produces evidence of prior complaints sufficient to show that the municipality and their officials ignored police misconduct. A failure to investigate or reprimand might also cause a future violation by sending a message to officers that such behavior is tolerated. However, the mere existence of previous citizens' complaints does not suffice to show a municipal custom of permitting or encouraging excessive force. Indeed, the number of complaints bears no relation to their validity. A plaintiff must also show that the municipality failed to investigate or take corrective action on any prior meritorious claim of excessive force. Civil Procedure > Pleading & Practice > Pleadings > Amendment of Pleadings Civil Procedure > Judgments > Summary Judgment > Motions for Summary Judgment HN14[] Pleadings, Amendment of Pleadings Issues raised for the first time in a plaintiff's response to a motion for summary judgment may be considered a request to amend the complaint, pursuant to Fed. R. Civ. P. 15. Civil Rights Law > Protection of Rights > Conspiracy Against Rights > Elements HN15[] Conspiracy Against Rights, Elements The essential elements of a 42 U.S.C.S. § 1985(3) conspiracy claim are: (1) a conspiracy; (2) to deprive plaintiff of equal protection or equal privileges and immunities; (3) an act in furtherance of the conspiracy; and (4) an injury or deprivation resulting therefrom. Civil Rights Law > Protection of Rights > Conspiracy Against Rights HN16[] Protection of Rights, Conspiracy Against Rights A 42 U.S.C.S. § 1985(3) conspiracy does not apply to all conspiratorial interferences with the rights of others, but only to conspiracies motivated by some racial, or perhaps otherwise class-based, invidiously discriminatory animus. Civil Rights Law > Protection of Rights > Conspiracy Against Rights HN17[] Protection of Rights, Conspiracy Against Rights A federal conspiracy action brought under 42 U.S.C.S. § 1983 requires at least a combination of two or more persons acting in concert and an allegation of a meeting of the minds, an agreement among the defendants, or a general conspiratorial objective. Civil Procedure > ... > Attorney Fees & Expenses > Basis of Recovery > Bad Faith Awards Civil Procedure > Judgments > Summary Judgment > Motions for Summary Judgment HN18[] Basis of Recovery, Bad Faith Awards Fed. R. Civ. P. 56(h) provides that the district court may order a party to pay reasonable expenses, including attorneys' fees, if the court finds that an affidavit or declaration under this rule is submitted in bad faith or solely for delay. Counsel: [*1] For Vicki (I) Lynn Trujillo, individually, Vicki Lynn Trujillo, on behalf of the Estate of Jason Gomez, Plaintiffs: Kenneth Alfredo Padilla, LEAD ATTORNEY, Padilla & Padilla, PLLC, Denver, CO. For Timothy (I) Campbell, Timothy Campbell, as a Police Officer of the City and County of Denver, Gerald (I) R. Whitman, individually, Gerald R. Whitman, in his official capacity as Chief of Police of the City and County of Denver, City and County 2012 U.S. Dist. LEXIS 118585, *118585 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 76 of 106 Page 6 of 14 of Denver, a municipal corporation, Defendants: David Van Denberg Cooke, Denver City Attorney's Office, Denver, CO; Matthew Raymond Hader, Robert A. Wolf, Denver City Attorney's Office-West Colfax Avenue, Denver, CO. Judges: CHRISTINE M. ARGUELLO, United States District Judge. Opinion by: CHRISTINE M. ARGUELLO Opinion ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION FOR SUMMARY JUDGMENT This matter is before the Court on Defendants Timothy Campbell, Gerald R. Whitman, and the City and County of Denver (collectively, "Defendants") Motion and Brief for Summary Judgment, filed on December 19, 2011. (Doc. # 121.) For the reasons discussed below, the Court grants in part and denies in part Defendants' motion for summary judgment. I. BACKGROUND The following facts are undisputed, [*2] unless otherwise noted. The Court will elaborate, as needed, in its analysis section. In the early morning hours of December 19, 2007, Officer Campbell, a member of the Denver Police Department ("DPD"), was patrolling a residential area in Denver, Colorado. (Doc. # 121 at ¶ 4.) Just before 2:10 a.m., Officer Campbell observed a "dark colored four-door Saturn" driving in the opposite direction of his patrol car on Irving Street. (Id. at ¶¶ 4-5.) Officer Campbell decided to follow the Saturn, allegedly because he found it "suspicious." (Id. at ¶ 6-7.) As Officer Campbell trailed behind the Saturn, the Saturn turned east on Ohio Street and out of Officer Campbell's sight. Following onto Ohio Street, Officer Campbell spotted the Saturn stopped in the driveway of the first house on his right. (Id. at ¶ 12.) When Officer Campbell exited his patrol vehicle, he observed Jason Gomez "rapidly exit the car" and "immediately run away from the car through the residential neighborhood." (Id.) Officer Campbell gave chase on foot, eventually catching up to Mr. Gomez. An altercation ensued that culminated with Officer Campbell fatally shooting Gomez. Besides agreeing that Officer Campbell shot Mr. Gomez, [*3] the parties dispute virtually every other fact concerning the shooting. Officer Campbell attests that Mr. Gomez shouted that he was "gonna kill" Officer Campbell and shouted the initials of a violent street gang. Officer Campbell also attests that Mr. Gomez, who was "bobbing like a fighting cock," reached into his pocket and pulled out an object with a shiny tip, and rapidly moved his left hand with the object behind his back out of Officer Campbell's sight. (See Doc. # 121-1 at ¶¶ 14-19.) Although Mr. Gomez is unable to tell his side of the story, an eyewitness to the shooting, Max Alderton, tells a very different tale. Mr. Alderton attests that Mr. Gomez was kneeling down in front of Officer Campbell, that Officer Campbell shouted that he was going to kill Mr. Gomez, that Mr. Gomez did not make any threatening gestures, and that he did not see any object in Mr. Gomez's hand. Mr. Gomez tried to flee, and Officer Campbell shot him. After Mr. Gomez fell to the ground, Officer Campbell fired five to seven more shots. Plaintiff initiated this lawsuit on December 29, 2009. (Doc. # 3.) Pursuant to her Complaint, Plaintiff Vicki Lynn Trjiullo ("Plaintiff"), individually and on behalf of the [*4] Estate of Jason Gomez ("Gomez"), brings three claims for relief. First, she brings an excessive force claim under 42 U.S.C. § 1983 against Defendant Campbell ("Officer Campbell") and Defendant City and County of Denver ("Denver"). Second, she brings a § 1983 municipal liability claim against Defendant Whitman ("Chief Whitman") and Denver. Third, she brings a § 1985 conspiracy claim against all Defendants.1 (Doc. # 3.) 1 Plaintiff's Complaint also appears to allege a claim of the deprivation of familial association. (Doc. # 3 at 5.) In her Response, Plaintiff admits that this claim is not supported by 2012 U.S. Dist. LEXIS 118585, *1 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 77 of 106 Page 7 of 14 Plaintiff responded to Defendants' motion for summary judgment on February 29, 2012,2 and Defendants replied on May 14, 2012. (Doc. ## 142, 169.) II. STANDARD OF REVIEW A. SUMMARY JUDGMENT HN1[] Summary judgment is appropriate if the moving party demonstrates that there is "no genuine dispute as to any material fact" and that it is "entitled to a judgment as a matter of law." Fed. R. Civ. P. 56(a).In applying this standard, the Court views the evidence and all reasonable inferences therefrom in the light most favorable to the nonmoving party. Adler v. Wal-Mart Stores, Inc., 144 F.3d 664, 670 (10th Cir. 1998) (citing Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S. Ct. 1348, 89 L. Ed. 2d 538 (1986)).A fact is "material" if, under the applicable substantive law, it is "essential [*6] to the proper disposition of the claim." Id. (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S. Ct. 2505, 91 L. Ed. 2d 202 (1986)). A dispute of fact is "genuine" if "there is sufficient evidence on each side so that a rational trier of fact could resolve the issue either way." Id. (citing Anderson, 477 U.S. at 248). HN2[] The moving party bears the initial burden the facts, and Plaintiff has therefore withdrawn this claim. 2 On February 29, 2012, the Court granted Plaintiff's Motion for Leave to File Excess Pages. (Doc. # 143.) When the Court permits a party to exceed its page limit requirements, the Court expects that the party will do its utmost to conform as closely as possible to the page limits. Plaintiff, however, filed an 83-page response brief, which exceeds the Court's page limits by a robust 63 pages. [*5] CMA Civ. Practice Standards III.G.2 ("Motions and response briefs shall not exceed twenty pages) (emphasis in original). As if this were not long enough, Plaintiff then filed an 8-page supplement. (Doc. # 157.) Plaintiff's decision to file a 91-page response to Defendants' 30-page motion for summary judgment is an abuse of the Court's willingness to permit Plaintiff to exceed the page limits. The excessive length of Plaintiff's Response is especially frustrating because, as Defendants observe, the Response is both "prolix and rambling." (Doc. # 169 at 15 n.3.) of demonstrating an absence of a genuine issue of material fact and entitlement to judgment as a matter of law. Id. at 670-71. In attempting to meet that standard, a movant who does not bear the ultimate burden of persuasion at trial does not need to disprove the other party's claim; rather, the movant need simply point out to the court a lack of evidence for the other party on an essential element of that party's claim. Id. at 671 (citing Celotex Corp. v. Catrett, 477 U.S. 317, 325, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986)). Once the movant has met this initial burden, the burden shifts to the nonmoving party to "set forth specific facts showing that there is a genuine issue for trial." Anderson, 477 U.S. at 256. The nonmoving party may not simply rest upon its pleadings to satisfy its burden. Id. Rather, the nonmoving party must "set forth specific facts that would be admissible in [*7] evidence in the event of trial from which a rational trier of fact could find for the nonmovant." Adler, 144 F.3d at 671. "To accomplish this, the facts must be identified by reference to affidavits, deposition transcripts, or specific exhibits incorporated therein." Id. III. ANALYSIS A. EXCESSIVE FORCE CLAIM AGAINST DEFENDANT CAMPBELL Defendants argue that Officer Campbell is entitled to qualified immunity. HN3[] Under the doctrine of qualified immunity, government officials are protected "from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." Pearson v. Callahan, 555 U.S. 223, 232, 129 S. Ct. 808, 172 L. Ed. 2d 565 (2009) (quoting Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S. Ct. 2727, 73 L. Ed. 2d 396 (1982) (internal quotation marks omitted)). "Qualified immunity requires a 'two-step sequence.'" Morris v. Noe, 672 F.3d 1185, 1191 (10th Cir. 2012) (quoting Pearson, 555 U.S. 223, 129 S. Ct. 808, 172 L. Ed. 2d 565). "When a defendant asserts qualified immunity at summary 2012 U.S. Dist. LEXIS 118585, *4 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 78 of 106 Page 8 of 14 judgment, the burden shifts to the plaintiff to show that: (1) the defendant violated a constitutional right and (2) the constitutional right was clearly established." Id. (quoting Martinez v. Beggs, 563 F.3d 1082, 1088 (10th Cir. 2009). [*8] Only if a plaintiff can satisfy both steps will the assertion of qualified immunity be defeated. See id. In this case, Plaintiff asserts that Officer Campbell violated Mr. Gomez's Fourth Amendment rights to be free from unlawful seizure through the use of deadly force. (Doc. # 142 at 24.) HN4[] "Claims of excessive force are analyzed under the objective reasonableness standard of the Fourth Amendment." Medina v. Cram, 252 F.3d 1124, 1131 (10th Cir. 2001);see also Graham v. Connor, 490 U.S. 386, 395, 109 S. Ct. 1865, 104 L. Ed. 2d 443 (1989).Under this objective standard, the question is whether Officer Campbell's actions were objectively reasonable in light of the facts and circumstances confronting him, without regard to his underlying intent or motivation. See Morris, 672 F.3d at 1195 (citing Graham, 490 U.S. at 397).In determining whether the use of force was reasonable, the Court must pay careful attention to the facts and circumstances in this particular situation, "including the severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the officers or others, and whether he is actively resisting arrest or attempting to evade arrest by flight." Graham, 490 U.S. at 396). In this case, [*9] there are numerous facts in dispute.3 Viewing the disputed evidence in the light most favorable to Plaintiff, Officer Campbell was 3 Defendants argue that "the statements of partial witness Alderton and the testimony of Defendant Campbell are consistent." (Doc. # 169 at 17.) This is ludicrous. For example, Officer Campbell attests that Mr. Gomez yelled "I'm gonna kill you" as he made a threatening gesture. (Doc. # 121-1 at ¶ 17.) Defendants say in their brief that "Alderton stated he does not know who was shouting 'I'm gonna fucking kill you.'" (Doc. # 169 at 17.) However, in both his statement to the Denver Police Department and in his affidavit, Mr. Alderton asserts that Officer Campbell was the one yelling, "I am gonna fucking kill you!" (Doc. # 142-5; [*10] 142-1.) Defendants' distortion of the evidentiary record is, at best, an example of inexcusable carelessness; at worst, a blatant attempt to deceive this Court. shouting that he was going to kill Mr. Gomez as Mr. Gomez knelt before Officer Campbell. When Mr. Gomez turned to flee, Officer Campbell fired one shot at Mr. Gomez who fell to the ground. After a brief pause, Officer Campbell fired five to seven more shots at Mr. Gomez. Mr. Alderton did not see Mr. Gomez make any threatening gestures during the exchange and did not see Mr. Gomez have anything in his hand. (Doc. # 142-5 at ¶¶ 6-12.) Based on these facts, the Court finds that all three of the Graham factors weigh heavily in Plaintiff's favor. Under the first factor, the Court considers the severity of the crime at issue. Here, there was no crime at issue. Officer Campbell attests only that he was "suspicious that [Mr. Gomez] was involved in criminal activity." (Doc. # 121-1 at ¶ 10.) It appears undisputed that Officer Campbell did not have reason to suspect Mr. Gomez of committing any specific crime. The second factor — whether the suspect poses an immediate threat to the safety of the officer or others — also weighs strongly in Plaintiff's favor. HN5[] No reasonable officer would have reason to believe that a fleeing person not suspected of any specific crime and who had not made any threatening gestures posed any danger. At first blush, the third factor — whether Mr. Gomez was actively resisting arrest or attempting to flee — appears to tilt in Defendants' favor as Mr. Gomez was attempting to flee when he was shot. However, viewing the evidence in the light [*11] most favorable to Plaintiff, Mr. Gomez's attempt to flee was the result of Officer Campbell's own deliberate or reckless conduct when he threatened to kill Mr. Gomez. See Allen v. Muskogee, Okla., 119 F.3d 837, 840 (10th Cir. 1997) (noting that HN6[] the reasonableness of an officer's conduct may depend on whether the officer's own deliberate or reckless conduct created the need to use deadly force). Thus, Plaintiff has presented sufficient evidence to raise triable issues that Officer Campbell violated Mr. Gomez's Fourth Amendment rights. Having determined that Plaintiff may be able to prove a Fourth Amendment violation, the Court turns to the second qualified immunity prong. HN7[ ] "The relevant, dispositive inquiry in determining whether a right is clearly established is whether it 2012 U.S. Dist. LEXIS 118585, *7 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 79 of 106 Page 9 of 14 would be clear to a reasonable officer that his conduct was unlawful in the situation he confronted." Saucier v. Katz, 533 U.S. 194, 202, 121 S. Ct. 2151, 150 L. Ed. 2d 272 (2001).The question of whether a right is clearly established must be addressed in light of the specific context of the case. See id. That is, the question is not whether there exists a general right to be free from excessive force, but whether Mr. Gomez had a clearly established [*12] right under the facts of this case. See Morris, 672 F.3d at 1196. Viewing the disputed evidence in the light most favorable to Plaintiff, there can be no serious doubt that Officer Campbell's alleged conduct violated clearly established rights. The Supreme Court has held that "[w]here the suspect poses no immediate threat to the officer and no threat to others, the harm resulting from failing to apprehend him does not justify the use of deadly force to do so." Tennessee v. Garner, 471 U.S. 1, 11, 105 S. Ct. 1694, 85 L. Ed. 2d 1 (1985). In other words, "[a] police officer may not seize an unarmed, nondangerous suspect by shooting him dead." Id.; accord Carr v. Castle, 337 F.3d 1221, 1227 (10th Cir. 2003). Thus, Supreme Court and Tenth Circuit precedent clearly establishes that a police officer may not use deadly force to seize an unarmed and nondangerous suspect who flees from a police officer. Construing the disputed evidence in the light most favorable to Plaintiff, the Court finds that Officer Campbell violated Mr. Gomez' clearly established rights under the Fourth Amendment. Thus, Officer Campbell is not entitled to qualified immunity and judgment is not appropriate as a matter of law. Whether Officer Campbell actually [*13] violated Mr. Gomez's Fourth Amendment rights is a matter to be determined at trial. B. MUNICIPAL LIABILITY CLAIM PURSUANT TO 42 U.S.C. ' 1983 HN8[] A municipality may not be held liable under § 1983 merely on the basis of its status as an employer. Rather, to establish municipal liability, a plaintiff must demonstrate two elements: (1) a municipal employee committed a constitutional violation; and (2) a direct causal link between the injury alleged and a municipal policy or custom. Bryson v. City of Okla. City, 627 F.3d 784, 788 (10th Cir. 2010). For purposes of the instant summary judgment motion, the Court has already found that Plaintiff has provided sufficient evidence to create triable issues on the question of whether Officer Campbell violated Mr. Gomez's Fourth Amendment rights. Thus, the issue is whether Plaintiff can show a direct causal link between Denver's policies or customs and the constitutional injury. Plaintiff's response to Defendants' motion for summary judgment identifies the following theories for municipality liability under § 1983: (1) failure to train of supervise police officers properly on the use of force including deadly force; (2) failure to discipline officers who [*14] use deadly force; (3) failure to properly supervise Officer Campbell and other Denver Police Officers; and (4) failure to properly investigate police shootings.4 (Doc. # 142 at 44.) The Court examines each in turn. 1. Failure to Train Plaintiff first theory for municipality under § 1983 is her allegation that Denver failed to adequately train its police officers. HN9[] To establish a claim for failure to train, Plaintiff must first prove that the training was, in fact, inadequate. If Plaintiff can [*15] do so, she must then satisfy the following requirements: (1) the officers exceeded constitutional limitations on the use of force; (2) the use of force arose under circumstances that constitute a usual and recurring situation with which police officers must deal; (3) the 4 The Court notes that Plaintiff has not complied with the Court's practice standards, which instructs parties opposing summary judgment to include a separate section of her brief in order to "set forth in simple declarative sentences . . .each additional material disputed fact which undercuts movant's claim that movant is entitled to judgment as a matter of law." CMA Civ. Practice Standards III.G.6. With one exception, Plaintiff utterly disregards this instruction and provides no facts relating to her municipal liability claim (the one exception being that Plaintiff has identified the average percentage of sustained complaints against Denver police officers from 1994 to 2007). (Doc. # 142 at 23.) 2012 U.S. Dist. LEXIS 118585, *11 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 80 of 106 Page 10 of 14 inadequate training demonstrates a deliberate indifference on the part of the city toward persons with whom the police officers come into contact, and (4) there is a direct causal link between the constitutional deprivation and the inadequate training. Brown v. Gray, 227 F.3d 1278, 1286 (10th Cir. 2000) (quoting Allen v. Muskogee, 119 F.3d 837, 841-42 (10th Cir. 1997)). Plaintiff's first argument as to Denver's alleged inadequate training regards her allegation that the DPD is not accredited by the Commission on Accreditation for Law Enforcement Agencies ("CALEA").5 (Doc. # 142 at 47.) According to Plaintiff, CALEA requires police departments to provide mandatory periodic re-training to its officers on use of force policy and law. (Id.) Plaintiff argues that because the DPD is not a CALEA accredited police department, it therefore fails to provide its officers such training. This is a logical fallacy. The fact that the [*16] DPD is not a CALEA accredited police department is not evidence that the DPD fails to provide adequate training to its officers.6 Plaintiff also claims that the DPD's training materials "distort[ ] the perception of police officers and creates a mindset that [*17] they believe that they are going to be killed or ambushed at any moment." (Doc. # 142 at 53.) Plaintiff also criticizes the training materials for failing to indicate that "law enforcement work is not as dangerous as many 5 Although Plaintiff does not cite to any evidence showing that the DPD is not accredited by the CALEA, Defendants' reply seems to admit this fact. (Doc. # 169 at 26.) However, as Defendants note, Plaintiff fails to explain the relevance of this non-accreditation. Although there are allegedly 389 police departments that are CALEA accredited, there are nearly 17,000 law enforcement agencies across the United States. 6 Plaintiff cites to Zuchel v. City & County of Denver, in which the Tenth Circuit concluded that the DPD's failure to provide periodic live decisional shooting training constituted sufficient evidence of deliberate indifference. See 997 F.2d 730, 740-41 (10th Cir. 1993). Plaintiff contends that the Zuchel decision put Denver on notice that it needed to provide periodic training. Although constructive notice could be imputed from Zuchel, there is no evidence in the record that the DPD has failed to provide periodic training. other occupations." Although common sense makes it difficult to accept Plaintiff's contentions about the dangerousness of law enforcement work, Plaintiff has, perhaps, raised triable issues on the question of whether the City's training distorts the dangerousness of the job.7 Nevertheless, Plaintiff cannot survive summary judgment on her failure to train claim because she has provided no evidence of deliberate indifference on the part of Denver with respect to the training materials. HN10[] To show deliberate indifference, Plaintiff must present facts showing that "the municipality has actual or constructive notice that its action or failure to act is substantially certain to result in a constitutional violation, and it consciously or deliberately chooses to disregard the risk of harm." Bryson, 627 F.3d at 789 (quoting Barney v. Pulsipher, 143 F.3d 1299, 1307 (10th Cir. 1998)). In the specific context of inadequate training, deliberate indifference is shown when "the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, that the policymakers of the city can reasonably be said to have been deliberately indifferent to the need." Carr v. Castle, 337 F.3d 1221, 1229 (10th Cir. 2003). The Court finds that Plaintiff has not [*19] presented facts sufficient to meet this demanding standard. No reasonable juror could conclude that Denver had notice that either the few isolated poems and cartoons or the omissions of statistics regarding the fatality rate for police officers made it "substantially certain" that its 7 Plaintiff also argues that the Denver Police Department training materials erroneously instruct police officers that they may use deadly force upon their own subjective beliefs. Plaintiff has provided the Court with no evidence to support this argument. Although Plaintiff quotes from the DPD Operations Manual, Plaintiff has not attached the relevant sections to her motion so the Court cannot determine whether Plaintiff's quotations are accurate or taken in context. This is a recurring problem in Plaintiff's Response. For future cases, the Court reminds Plaintiff's counsel that the non-moving party must "set forth specific facts that would be admissible in evidence in the event of trial." Adler, 144 F.3d at 671. [*18] To accomplish this, such facts must be identified by reference to affidavits, deposition transcripts, or specific exhibits incorporated therein." Id. (emphasis added). 2012 U.S. Dist. LEXIS 118585, *15 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 81 of 106 Page 11 of 14 officers would engage in an unlawful use of deadly force.8 Lobato v. Ford, Case No. 05-cv-01437. 2007 U.S. Dist. LEXIS 82373, Doc. # 266 at 17, (D. Colo. Oct. 31, 2007) (unpublished) (rejecting virtually identical claim on grounds that Plaintiff had failed to show that Denver was deliberately indifferent). 2. Failure to Discipline Plaintiff's second theory of municipal liability is her allegation that Denver has an unwritten policy or custom of failing to discipline its police officers for excessive force violations. HN11[] Plaintiff must show genuine disputes of material fact that Denver had in place (1) a custom or policy of failure to discipline; (2) deliberate indifference on the part of a policy maker, and (3) a causal link to the constitutional deprivation. See Gates v. Unified Sch. Dist. No. 449 of Leavenworth Ctny., Kan., 996 F.2d 1035, 1041 (10th Cir. 1993). To [*20] support her § 1983 claim based on Denver's alleged failure to discipline its officers for the use of excessive force, Plaintiff highlights the fact that from 1994 to 2007, DPD officials sustained only 1.16% of excessive use of force complaints brought against its officers (Doc. # 142- 24.) According to Louis A. Mayo, Ph.D., Plaintiff's expert on police policies and practices, the national average for sustained rates for use of force complaints for large state and local law enforcement agencies is approximately 8%. (Doc. # 142-8 at ¶ 25.) Dr. Mayo opines that the "extremely low sustained rate for excessive force complaints by the DPD demonstrates that the Department is deliberately indifferent to complaints of excessive force and condones the use of excessive force by its officers." (Id.) In Lobato, another court in this district concluded that similar statistical evidence, standing alone, was sufficient to create a triable issue as to the existence of such a policy.9 See Case No. 05-cv- 8 Moreover, as Defendants point out, Plaintiff has provided no evidence indicating how these materials are actually used in training. 9 Plaintiff cites several pages of a deposition transcript taken in 01437, Doc. # 266 at 20. However, the Court finds that the statistical evidence presented by Plaintiff is too generalized for a reasonable jury to infer a custom of policy from it. First, Plaintiff's statistical [*21] evidence does not specify what proportion of the excessive force complaints were deadly force complaints.10 Second, Dr. Mayo does not explain how he reached his opinion that the DPD was "deliberately indifferent" based only on the small number of sustained complaints. There is no evidence that the allegations of excessive force in any other case were similar to the instant case. See Merman v. City of Camden, 824 F. Supp. 2d 581, 591 (D.N.J. 2010) (stating that a plaintiff must show why "prior incidents deserved discipline and how the misconduct in those situations was similar to the present one"). Moreover, although Lobato found that statistical evidence alone was sufficient to withstand summary judgment, several circuit courts have reached the opposite conclusion. See Thomas v. City of Chattanooga, 398 F.3d 426, 432 (6th Cir. 2005) (finding that expert's conclusion of municipal policy of condoning use of excessive force based on mere number complaints was insufficient to create genuine issue of material fact regarding the existence of such policy); Strauss v. City of Chicago, 760 F.2d 765, 768-69 (7th Cir. 1985) (finding statistics alone insufficient to prove municipal liability); see also Merman v. City of Camden, 824 F. Supp. 2d 581, 591 (D.N.J. 2010) ("Isolated and without further context . . . statistical evidence alone may not justify a jury's finding that the Lobato case of Mr. Alvin LaCabe, the Manager of Safety at the time. (Doc. # 142-26.) As the Lobato court found, Mr. LaCabe's deposition testimony does not constitute evidence of Denver's alleged policy not to discipline its police officers for excessive force. Case No. 05-cv-01437 (Doc. # 266 at 20.) Thus, Plaintiff's statistical evidence is the only evidence that supports her failure to discipline claim. 10 In her Supplement, Plaintiff lists sixteen incidents where a Denver Police Officer allegedly used deadly force. (Doc. [*22] # 157 at 2-3.) Plaintiff claims that no complaints were sustained against any of the officers. However, Plaintiff has presented no evidence to substantiate either that the incidents occurred or that any resulting complaints were not sustained. As such, the shooting incidents are mere allegations and not evidence that the Court may properly consider on summary judgment. See supra note 7. 2012 U.S. Dist. LEXIS 118585, *18 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 82 of 106 Page 12 of 14 a municipal policy or custom authorizes [*23] or condones the unconstitutional acts of police officers."). Given the generalized nature of Plaintiff's statistical evidence, and the lack of evidence that more complaints should have been sustained, the Court finds that Plaintiff has not created a triable issue as to the existence of a municipal custom or policy. Assuming arguendo that Plaintiff has shown genuine disputes of material fact as to the existence of such a municipal policy or custom, Plaintiff's failure to discipline claim would fail for a separate reason. HN12[] To prevail on a § 1983 municipal liability claim, Plaintiff must show a causal link between the policy and constitutional deprivation. In her Response, Plaintiff asserts that she has "shown a direct causal link" without explaining how she has accomplished such a task or what evidence supports this assertion.11 (Doc. # 142 at 72.) Such a conclusory assertion does not create a genuine dispute of material fact to defeat summary judgment on this claim. 3. Failure to Supervise Plaintiff third theory of municipal liability is labeled as "failure to properly supervise." However, this claim appears largely to be an offshoot of her failure to discipline claim, except that it is focused on the DPD's failure to discipline Officer Campbell specifically. For purposes of this motion, the Court assumes as true that, from 2002 through 2006, Officer Campbell received six excessive force complaints, none of which were sustained. (Doc. # 142-19.) HN13[] In some circumstances, a municipality may be held liable where the plaintiff produces evidence of prior complaints sufficient to show that the municipality and their officials ignored police 11 Based on Plaintiff's argument in a separate section of her brief, it appears that Plaintiff's theory is that Officer Campbell committed the alleged constitutional violation because he thought he could escape culpability. [*24] (Doc. # 142 at 50.) There is no evidence to support this argument. Compare with Lobato, Case No. 05-cv-01437, Doc. # 266 at 21-22 (the plaintiff supplied evidence that the police officer had said that he knew he would not lose his job even if he shot someone wrongfully). misconduct. See Mettler v. Whitledge, 165 F.3d 1197, 1205 (8th Cir. 1999);see also Cordova v. Aragon, 569 F.3d 1183, 1194 (10th Cir. 2009) ("A failure to investigate or reprimand might also cause a future violation by sending a message to officers that [*25] such behavior is tolerated."). However, "the mere existence of previous citizens' complaints does not suffice to show a municipal custom of permitting or encouraging excessive force."Mettler, 165 F.3d at 1205;Brooks v. Scheib, 813 F.2d 1191, 1193 (11th Cir. 1987) ("Indeed, the number of complaints bears no relation to their validity."). A plaintiff must also show that the municipality failed to investigate or take corrective action on any prior meritorious claim of excessive force.See id.; Lewis v. Bd. of Sedgwick Ctny. Comm'rs, 140 F. Supp. 2d 1125, 1138 (D. Kan. 2001) (holding that defendant municipality was entitled to judgment as a matter of law where the plaintiff failed to present any evidence that the municipality failed to take corrective action on any prior meritorious complaint); Gantos v. City of Colo. Springs Police Dep't, No. 07-cv-00036, 2008 U.S. Dist. LEXIS 12465, 2008 WL 296291, at *9 (D. Colo. Feb. 20, 2008) (unpublished) ("Absent some showing that the previous complaints had merit, and that the [police department] avoided or ignored meritorious complaints, such previous complaints do not support a municipal liability claim."); Long v. City & Ctny. of Honolulu, 378 F. Supp. 2d 1241, 1247 (D. Haw. 2005) [*26] (finding that "prior complaints or incidents do not establish 'deliberate indifference' regarding a failure to train or discipline."). Although the existence of several excessive force complaints against Officer Campbell prior to the fatal shooting of Mr. Gomez raises some suspicions, Plaintiff has failed to present any evidence showing that Denver failed to take disciplinary or corrective action on any prior meritorious claim of excessive force against Officer Campbell. Without such evidence, Plaintiff has not established a municipal custom or policy of permitting or encouraging excessive force.12 See 12 In this section of her brief, Plaintiff also makes a difficult to decipher argument that Denver's alleged policy or custom of failing to discipline its officers for false statements caused an 2012 U.S. Dist. LEXIS 118585, *22 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 83 of 106 Page 13 of 14 Mettler, 165 F.3d at 1205. Thus, summary judgment is appropriate on Plaintiff's "failure to supervise" claim. 4. Failure to Investigate Plaintiff's final theory of municipal liability concerns Denver's alleged failure to properly investigate [*27] police shootings. In their Reply, Defendants correctly note that this theory of liability was not pled in Plaintiff's Complaint. As such, the issue is properly considered as a request to amend the complaint. See Viernow v. Euripides Dev. Corp., 157 F.3d 785, 790 n.9 (10th Cir. 1998) (HN14[] "Issues raised for the first time in a plaintiff's response to a motion for summary judgment may be considered a request to amend the complaint, pursuant to Fed. R. Civ. P. 15."). The Court finds that such amendment would be futile. It is unclear whether Plaintiff contends that Denver's alleged "failure to investigate" is a freestanding theory of municipal liability, or a corollary of her "failure to discipline" and "failure to supervise" claim. What is clear is that Plaintiff has not directed the Court to any case law showing that "failure to investigate" is a viable basis for municipal liability, nor has Plaintiff attempted to identify the elements of such a claim. Although Plaintiff raises legitimate questions about the thoroughness of Denver's investigation of Officer Campbell's shooting of Mr. Gomez, (Doc. # 142 at 78-79), the Court is unable to perceive how a lackluster post-shooting investigation [*28] could have caused Officer Campbell to violate Mr. Gomez's Fourth Amendment rights. See Cordova, 569 F.3d at 1194 ("basic principals [sic] of linear time prevent us from seeing how conduct that occurs after the alleged violation could have somehow caused that violation."). Thus, Plaintiff has not demonstrated a causal link between Denver's alleged failure to investigate and the constitutional violation. C. CONSPIRACY CLAIM UNDER 42 U.S.C. § excessive use of force against Mr. Gomez. As the Lobato court stated, "[t]he problems with this argument are manifest." Case No. 05-cv-01437, Doc. # 266 at 22-23. 1985 In this claim, Plaintiff alleges that Chief Whitman and Officer Campbell conspired to violate Mr. Gomez's constitutional rights under 42 U.S.C. § 1985(3).HN15[] "The essential elements of a § 1985(3) conspiracy claim are: (1) a conspiracy; (2) to deprive plaintiff of equal protection or equal privileges and immunities; (3) an act in furtherance of the conspiracy; and (4) an injury or deprivation resulting therefrom." Tilton v. Richardson, 6 F.3d 683, 686 (10th Cir. 1993). Plaintiff's evidence of a § 1985(3) conspiracy is woefully inadequate. First, she has offered no evidence that a conspiracy existed. Plaintiff alleges that there is circumstantial evidence of a "cover up," yet Plaintiff does not cite to any evidence in the record of a "cover up" or [*29] include any facts in her statement of the facts. Plaintiff's mere speculation that a conspiracy existed is not competent evidence to show the existence of a conspiracy. Assuming arguendo that Plaintiff could prove an unlawful conspiracy on the part of the individual defendants, HN16[] a § 1985(3) conspiracy does not apply to all conspiratorial interferences with the rights of others, but "only to conspiracies motivated by 'some racial, or perhaps otherwise class-based, invidiously discriminatory animus.'" Tilton, 6 F.3d at 686 (quoting Griffin v. Breckenridge, 403 U.S. 88, 102, 91 S. Ct. 1790, 29 L. Ed. 2d 338 (1971)). Plaintiff does not put forth any evidence in her statement of facts to support this element of a § 1985(3) claim. In the body of her argument, she alleges that Officer Campbell radioed in that he was involved in a foot chase with a "Hispanic male." (Doc. # 142 at 34.) Plaintiff appears to argue that the mere fact that Mr. Gomez was Hispanic and that Officer Campbell knew Mr. Gomez's race is sufficient evidence to infer a conspiracy based on racial discrimination. The Court disagrees. Plaintiff has provided no authority to support her argument, and the Court strongly suspects that none exists. Thus, summary judgment [*30] is appropriate on Plaintiff's § 2012 U.S. Dist. LEXIS 118585, *26 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 84 of 106 Page 14 of 14 1985(3) conspiracy claim.13 D. ATTORNEYS' FEES In her Response, Plaintiff requests that she be awarded attorneys' fees pursuant to Fed. R. Civ. P. 56(h) for having to respond to Defendants' Motion for Summary Judgment. (Doc. # 142 at 82-83.) HN18[]Rule 56(h) provides that the Court may order [*31] a party to pay reasonable expenses, including attorneys' fees, if the Court finds "that an affidavit or declaration under this rule is submitted in bad faith or solely for delay." Although Plaintiff disagrees with the facts recited in Officer Campbell's affidavit, the Court does not find that the affidavit was submitted "in bad faith or solely for delay." The Court agrees with Plaintiff that it was disingenuous for Defendants to present the facts stated in Officer Campbell's affidavit as "undisputed," given the major discrepancies between Officer Campbell's affidavit and Mr. Alderton's statement to the police. Indeed, there are so many hotly disputed material facts that, arguably, summary judgment should never have been brought on Plaintiff's excessive force claim. Nevertheless, Defendants' summary judgment motion was largely successful, and the Court will not order Defendants to pay attorneys' fees. IV. CONCLUSION Based on the foregoing, it is ORDERED that Defendants' Motion for Summary Judgment (Doc. 13 Defendants appear to credit Plaintiff with bringing a § 1983 conspiracy claim. (Doc. # 121 at 24-25.) However, it appears to the Court that Plaintiff's conspiracy claim is brought under § 1985(3) only. (Doc. # 3 at 10) ("Third Claim for Relief Against all Defendants Under 42 U.S.C. § 1985); (Doc. # 142 at 33) (arguing that Plaintiff has met the elements of a § 1985 conspiracy claim). To the extent that Plaintiff has alleged a § 1983 conspiracy claim, such a claim fails because, as discussed, Plaintiff has not provided any evidence that a conspiracy existed. See Brooks v. Gaenzle, 614 F.3d 1213, 1227-28 (10th Cir. 2010) (holding that HN17[] a federal conspiracy action brought under § 1983 "requires at least a combination of two or more persons acting in concert and an allegation of a meeting of the minds, an agreement among the defendants, or a general conspiratorial objective."). # 121) is GRANTED IN PART AND DENIED IN PART. Specifically, the Court GRANTS Defendants' Motion with respect to Plaintiff's § 1983 municipal liability claim against Denver and Plaintiff's [*32] § 1985 claim against all Defendants. Those claims are DISMISSED WITH PREJUDICE. The Court DENIES Defendants' Motion with respect to Plaintiff's § 1983 excessive force claim against Officer Campbell. It is FURTHER ORDERED that Defendants' Motion to Strike Plaintiff's Untimely Expert Opinions (Doc. # 172) is DENIED AS MOOT. DATED: August 22, 2012 BY THE COURT: /s/ Christine M. Arguello CHRISTINE M. ARGUELLO United States District Judge End of Document 2012 U.S. Dist. LEXIS 118585, *30 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 85 of 106 Positive As of: October 8, 2021 1:54 AM Z Velasquez v. Faulk United States District Court for the District of Colorado February 5, 2014, Decided; February 5, 2014, Filed Civil Action No. 12-cv-02057-WYD Reporter 2014 U.S. Dist. LEXIS 14845 *; 2014 WL 464000 JUAN VELASQUEZ, Applicant, v. WARDEN FAULK, L.C.F., and THE ATTORNEY GENERAL OF THE STATE OF COLORADO, Respondents. Subsequent History: Appeal dismissed by, Certificate of appealability denied, Motion granted by Velasquez v. Faulk, 2015 U.S. App. LEXIS 2817 (10th Cir., Feb. 25, 2015) Prior History:Velasquez v. Faulk, 2012 U.S. Dist. LEXIS 125906 (D. Colo., Sept. 5, 2012) Core Terms sentence, state court, trial counsel, deliberation, ineffective, clearly established federal law, convictions, trial court, proportionality, interview, first degree murder, voluntary intoxication, asserts, cases, grave, sufficient evidence, habitual criminal, disproportionality, witnesses, parole, conflicting interest, present evidence, intoxication, contends, remarks, counsel's performance, determining facts, plain error, fingerprint, quotation Counsel: [*1] Juan Velasquez, Petitioner, Pro se, Limon, CO. For Faulk, actually named as Warden Faulk, L.C.F., Attorney General of the State of Colorado, Respondents: Paul Edward Koehler, Colorado Attorney General's Office, Ralph L. Carr Colorado Judicial Center, Denver, CO. Judges: WILEY Y. DANIEL, SENIOR UNITED STATES DISTRICT JUDGE. Opinion by: WILEY Y. DANIEL Opinion ORDER ON APPLICATION FOR WRIT OF HABEAS CORPUS This matter is before me on the pro se Application for a Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2254 (ECF No. 6) ("Application") filed by Applicant Juan Velasquez. I. Background A jury convicted Velasquez of attempted first degree murder and first degree assault. His convictions arose from an incident in which he stabbed the victim with a knife while sitting behind him on a motorcycle. The trial court also found Velasquez to be a habitual criminal and imposed two concurrent ninety-six-year sentences. Velasquez moved pro se for a new trial pursuant to Crim. P. 33(c), arguing ineffective assistance of counsel and other matters. The trial court denied the motion. On direct appeal, a division of this court affirmed his convictions in People v. Velasquez, 2006 Colo. App. LEXIS 1889 (Colo. App. No. 03CA2449, Nov. 9, 2006) (not published pursuant [*2] to C.A.R. 35(f)). Velasquez subsequently sought relief pursuant to Crim P. 35(c), arguing he was denied a jury trial on the habitual criminal counts and he received ineffective assistance of counsel, but based on different allegations than contained Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 86 of 106 Page 2 of 21 in his motion under Crim. P. 33(c). The trial court denied his motion. People v. Velasquez, No. 07CA1796, 1-2, 2009 Colo. App. LEXIS 61 (Colo. App. Jan. 15, 2009). In Case No. 07CA1796, the Colorado Court of Appeals (CCA) affirmed the denial in part, reversed in part, and remanded for an evidentiary hearing on Applicant's ineffective assistance of counsel claim regarding a failure to investigate and raise the voluntary intoxication defense. 2009 Colo. App. LEXIS 61 [WL] at 11. After the remand hearing, the trial court again denied the Rule 35(c) postconviction motion and the CCA affirmed. Applicant petitioned for certiorari review and, according to Respondents, which Applicant does not deny, the Colorado Supreme Court (CSC) has yet to rule on the petition. Applicant then commenced this action on August 6, 2012, and filed an Amended Application on September 4, 2012. In the Amended Application, Applicant asserts: (1) Denial of a right to conflict free counsel; (2) Lack of sufficient evidence to [*3] support a charge of attempted first degree murder; (3) Lack of a sufficient indictment resulting in the inability to prepare a defense; (4) Lack of sufficient evidence to prove habitual criminal counts; (5) Disproportionate sentence; (6) Prosecutorial misconduct; (7) Ineffective assistance of trial counsel because (a) Counsel coerced Applicant not to testify; (b) Counsel failed to raise an affirmative defense of voluntary intoxication; (c) Counsel failed to conduct a reasonable investigation and interview witnesses in support of a voluntary intoxication defense; (d) Counsel failed to object to the prosecution's misstatements of law and misconduct in closing and rebuttal arguments; and (e) Cumulative error; and (8) Denial of a right to jury trial on habitual criminal findings. On February 1, 2013, I dismissed Claim Three as procedurally barred from federal habeas review and ordered Respondents to file an Answer. Respondents filed an Answer, ECF No. 21, on March 21, 2013. Applicant did reply to the Answer. After reviewing the file, including the Application, the Answer, and the state court record, I conclude that the Application should be denied and the case dismissed with prejudice for the following [*4] reasons. II. Legal Standard A.Pro Se Standard of Review Applicant is proceeding pro se. I, therefore, "review his pleadings and other papers liberally and hold them to a less stringent standard than those drafted by attorneys." Trackwell v. United States, 472 F.3d 1242, 1243 (10th Cir. 2007) (citations omitted);see also Haines v. Kerner, 404 U.S. 519, 520-21, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972). However, a pro se litigant's "conclusory allegations without supporting factual averments are insufficient to state a claim on which relief can be based." Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991). A court may not assume that an applicant can prove facts that have not been alleged, or that a respondent has violated laws in ways that an applicant has not alleged. Associated Gen. Contractors of Cal., Inc. v. Cal. State Council of Carpenters, 459 U.S. 519, 526, 103 S. Ct. 897, 74 L. Ed. 2d 723 (1983).An applicant's pro se status does not entitle him to an application of different rules. See Montoya v. Chao, 296 F.3d 952, 958 (10th Cir. 2002). B.28 U.S.C. § 2254 Title 28 U.S.C. § 2254(d) provides that a writ of habeas corpus may not be issued with respect to any claim that was adjudicated on the merits in state court, unless the state court adjudication: (1) [*5] resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, 2014 U.S. Dist. LEXIS 14845, *2 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 87 of 106 Page 3 of 21 as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. 28 U.S.C. § 2254(d). Claims of legal error and mixed questions of law and fact are reviewed pursuant to 28 U.S.C. § 2254(d)(1).See Cook v. McKune, 323 F.3d 825, 830 (10th Cir. 2003).The threshold question pursuant to § 2254(d)(1) is whether Applicant seeks to apply a rule of law that was clearly established by the Supreme Court at the time his conviction became final. See Williams v. Taylor, 529 U.S. 362, 390, 120 S. Ct. 1495, 146 L. Ed. 2d 389 (2000). Clearly established federal law "refers to the holdings, as opposed to the dicta, of [the Supreme] Court's decisions as of the time of the relevant state-court decision." Id. at 412. Furthermore, clearly established law consists of Supreme Court holdings in cases where the facts are at least closely-related or similar to the case sub judice. Although the legal rule at issue need not have had its genesis in the closely-related or similar factual [*6] context, the Supreme Court must have expressly extended the legal rule to that context. House v. Hatch, 527 F.3d 1010, 1016 (10th Cir. 2008). If there is no clearly established federal law, that is the end of my inquiry pursuant to § 2254(d)(1).See id. at 1018.If a clearly established rule of federal law is implicated, I must determine whether the state court's decision was contrary to or an unreasonable application of that clearly established rule of federal law. See Williams, 529 U.S. at 404- 05. A state-court decision is contrary to clearly established federal law if: (a) "the state court applies a rule that contradicts the governing law set forth in Supreme Court cases"; or (b) "the state court confronts a set of facts that are materially indistinguishable from a decision of the Supreme Court and nevertheless arrives at a result different from [that] precedent." Maynard [v. Boone], 468 F.3d [665,] 669 [ (10th Cir. 2006) ] (internal quotation marks and brackets omitted) (quoting Williams, 529 U.S. at 405)."The word 'contrary' is commonly understood to mean 'diametrically different,' 'opposite in character or nature,' or 'mutually opposed.'" Williams, 529 U.S. at 405 [*7] (citation omitted). A state court decision involves an unreasonable application of clearly established federal law when it identifies the correct governing legal rule from Supreme Court cases, but unreasonably applies it to the facts. Id. at 407-08.Additionally, we have recognized that an unreasonable application may occur if the state court either unreasonably extends, or unreasonably refuses to extend, a legal principle from Supreme Court precedent to a new context where it should apply. House, 527 F.3d at 1018. My inquiry pursuant to the "unreasonable application" clause is an objective one. See Williams, 529 U.S. at 409-10."[A] federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather that application must also be unreasonable." Id. at 411."[A] decision is 'objectively unreasonable' when most reasonable jurists exercising their independent judgment would conclude the state court misapplied Supreme Court law." Maynard, 468 F.3d at 671. In addition, evaluating whether a rule application was unreasonable requires considering [*8] the rule's specificity. The more general the rule, the more leeway courts have in reaching outcomes in case-by-case determinations. It is not an unreasonable application of clearly established Federal law for a state court to decline to apply a specific legal rule that has 2014 U.S. Dist. LEXIS 14845, *5 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 88 of 106 Page 4 of 21 not been squarely established by [the Supreme] Court. Harrington v. Richter, 131 S. Ct. 770, 786, U.S. , 178 L. Ed. 2d 624 (Jan. 19, 2011) (internal quotation marks and citation omitted). I "must determine what arguments or theories supported or . . . could have supported[ ] the state court's decision" and then "ask whether it is possible fairminded jurists could disagree that those arguments or theories are inconsistent with the holding in a prior decision of [the Supreme] Court." Id. "Even a strong case for relief does not mean the state court's contrary conclusion was unreasonable." Id. (citation omitted). "Section 2254(d) reflects the view that habeas corpus is a guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal." Id. (citation omitted). Under this standard, "only the most serious misapplications of Supreme Court precedent will be a basis [*9] for relief under § 2254."Maynard, 468 F.3d at 671.Furthermore, [a]s a condition for obtaining habeas corpus relief from a federal court, a state prisoner must show that the state court's ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement. Richter, 131 S. Ct. at 786-87.Applicant bears the burden of proof under § 2254(d).See Woodford v. Visciotti, 537 U.S. 19, 25, 123 S. Ct. 357, 154 L. Ed. 2d 279 (2002) (per curiam). Claims of factual error are reviewed pursuant to 28 U.S.C. § 2254(d)(2).See Romano v. Gibson, 278 F.3d 1145, 1154 n.4 (10th Cir. 2002).Section 2254(d)(2) allows a court to grant a writ of habeas corpus only if the state court decision was based on an unreasonable determination of the facts in light of the evidence presented. Pursuant to § 2254(e)(1), I must presume that the state court's factual determinations are correct and Applicant bears the burden of rebutting the presumption by clear and convincing evidence. "The standard is demanding but not insatiable . . ." [because] '[d]eference does not by definition preclude relief.'" Miller-El v. Dretke, 545 U.S. 231, 240, 125 S. Ct. 2317, 162 L. Ed. 2d 196 (2005) [*10] (quoting Miller-El v. Cockrell, 537 U.S. 322, 340, 123 S. Ct. 1029, 154 L. Ed. 2d 931 (2003)). A claim, however, may be adjudicated on the merits in state court even in the absence of a statement of reasons by the state court for rejecting the claim. Richter, 131 S. Ct. at 784. ("[D]etermining whether a state court's decision resulted from an unreasonable legal or factual conclusion does not require that there be an opinion from the state court explaining the state court's reasoning"). Furthermore, "[w]hen a federal claim has been presented to a state court and the state court has denied relief, it may be presumed that the state court adjudicated the claim on the merits in the absence of any indication or state-law procedural principles to the contrary." Id. at 784-85. Even "[w]here a state court's decision is unaccompanied by an explanation, the habeas petitioner's burden still must be met by showing there was no reasonable basis for the state court to deny relief." Id. at 784.Although Richter concerned a state-court order that did not address any of the defendant's claims, its presumption is applicable when a state-court opinion addresses some but not all of those claims. Johnson v. Williams, U.S. , 133 S. Ct. 1088, 1094-98, 185 L. Ed. 2d 105 (2013). In [*11] other words, I "owe deference to the state court's result, even if its reasoning is not expressly stated."Aycox v. Lytle, 196 F.3d 1174, 1177 (10th Cir. 1999).Therefore, I "must uphold the state court's summary decision unless [the court's] independent review of the record and pertinent federal law persuades [it] that [the] result contravenes or unreasonably applies clearly established federal law, or is based on an unreasonable determination of the facts in light of the evidence presented." Id. at 1178. "[T]his 'independent review' should be distinguished from a full de novo review of the petitioner's claims." Id. Likewise, I apply the AEDPA deferential standard of review when a state court adjudicates a federal 2014 U.S. Dist. LEXIS 14845, *8 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 89 of 106 Page 5 of 21 issue relying solely on a state standard that is at least as favorable to the petitioner as the federal standard. See Harris v. Poppell, 411 F.3d 1189, 1196 (10th Cir. 2005).If a claim was not adjudicated on the merits in state court, and if the claim also is not procedurally barred, I must review the claim de novo and the deferential standards of § 2254(d) do not apply. See Gipson v. Jordan, 376 F.3d 1193, 1196 (10th Cir. 2004). III. Analysis A. Claim One In his first claim, [*12] Applicant asserts that he was denied his right to conflict free counsel. Applicant specifically asserts that trial counsel refused to invoke his speedy trial rights under the Uniform Mandatory Disposition of Detainers Act (UMDDA) in violation of his right to conflict free counsel under the Sixth Amendment. Application at 5. Applicant contends that after he was arrested, charged, and appointed counsel he was transferred to the Colorado Department of Corrections because of a parole violation. Id. Applicant further contends when he informed counsel that he wished to exercise his ninety-day speedy trial right under the UMDDA counsel told him that he was unprepared for trial, because he had not interviewed witnesses or taken any other action in the case. Id. Counsel further told Applicant that he would have to waive his speedy trial rights, but if Applicant wished to proceed he would have to do so on his own. Id. Finally, Applicant asserts that the trial court found counsel was not ineffective and new counsel was not required because the situation was no more than a disagreement between Applicant and counsel. Id. Applicant does not argue how established federal law might support a possible [*13] conflict of interest claim or how the state court decision rejecting his conflict of interest claim is contrary to, or an unreasonable application of, any clearly established federal law. See 28 U.S.C. § 2254(d)(1). It was clearly established when Applicant was convicted that a defendant has a Sixth Amendment right to the effective assistance of counsel. See Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984).Ordinarily, a litigant asserting a claim that counsel was ineffective must demonstrate both that counsel's performance fell below an objective standard of reasonableness and that counsel's deficient performance resulted in prejudice to his defense. See id. at 687. "An 'actual conflict,' for Sixth Amendment purposes, is a conflict of interest that adversely affects counsel's performance." Mickens v. Taylor, 535 U.S. 162, 172 n.5, 122 S. Ct. 1237, 152 L. Ed. 2d 291 (2002). In addressing this claim, the CCA found as follows. I. Requests for Substitute Counsel Defendant first contends that, in violation of his constitutional rights, the trial court abused its discretion by denying his requests for substitute appointed counsel. He states that he explicitly requested new counsel, and argues that the court did not make sufficient [*14] inquiry into his reasons for dissatisfaction. We discern no abuse of discretion. An indigent defendant is entitled to effective representation, though not to counsel of his or her choice. People v. Jenkins, 83 P.3d 1122, 1125 (Colo. App. 2003). However, once a defendant voices his or her objections to court appointed counsel, the trial court must inquire into the defendant's reasons for dissatisfaction. People v. Fisher, 9 P.3d 1189, 1193 (Colo. App. 2000).If the defendant meets his or her burden of showing good cause, for example by showing a conflict of interest or a complete breakdown of communication, then the trial court must appoint substitute counsel. People v. Jenkins, supra, 83 P.3d at 1126. But if the court determines that the attorney- client relationship has not deteriorated beyond the point where counsel could provide effective assistance, then the court may refuse to appoint new counsel. The court's ruling will not 2014 U.S. Dist. LEXIS 14845, *11 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 90 of 106 Page 6 of 21 be disturbed absent an abuse of discretion. People v. Jenkins supra, 83 P.3d at 1126. Here, defendant requested new counsel twice before trial, complaining of a breakdown in communication. Contrary to defendant's assertions, our review of the record shows that [*15] upon both of defendant's requests, the court's inquiry was adequate. Specifically, the record reveals that upon defendant's first request, the court scheduled and then held a hearing to inquire into defendant's reasons for dissatisfaction. The court asked defense counsel, the People, and defendant for their perspectives on defendant's request. Defense counsel told the court that defendant had indicated he did not trust counsel or believe in his legal advice. He stated that he was in an awkward position because defendant's lack of trust had resulted in the breakdown of communication. When the court asked defendant for his perspective, he stated: "Well, I just don't feel that [defense counsel] is working in my best interests and we don't really have -- we don't see eye to eye and I would like different counsel." After further discussion, the court addressed the issues raised by defendant. Although defendant did not refer to his previous waiver of speedy trial or his pro se petition under the Uniform Mandatory Disposition of Detainers Act (UMDDA) at the hearing on his motion, the court nevertheless addressed those issues because defendant had previously mentioned them to the court. The court [*16] found that defendant's speedy trial and UMDDA arguments did not demonstrate a complete breakdown of communication because defense counsel did not know of defendant's intention to invoke the UMDDA and because defendant's speedy trial waiver was voluntary. Moreover, the court concluded: The court finds the state of the record at this time establishes that this is simply -- strike that that this is a disagreement between the defendant and [defense counsel] concerning matters and there has been no specific showing in this court's view of good cause shown to substitute counsel. Therefore the motion is denied. Defendant renewed his request for a new attorney on the date trial was scheduled to begin. The court again directly asked defendant why he was dissatisfied with his court-appointed counsel. Defendant explained that he believed his attorney was ineffective because he had not interviewed a potential witness. He also stated that he thought his attorney was not acting in his best interests when the attorney advised him to waive his speedy trial rights. He said he felt misled. Then, in "making an inquiry of [defense counsel]," the court questioned defense counsel on the issues raised by defendant. [*17] The court then again denied defendant's motion for appointment of substitute counsel. In light of the court's questions, its interview with counsel, defendant's responses, and the information already before the court each time defendant requested substitute counsel, we are satisfied that the court adequately inquired into the reasons for defendant's dissatisfaction, including the issues of his speedy trial waiver, his UMDDA petition, and his lack of trust in defense counsel. Furthermore, notwithstanding defense counsel's statement that there was a breakdown in communication, the court's determination that the relationship had not deteriorated to the point of a complete breakdown has record support. See People v. Arguello, 772 P.2d 87, 94 (Colo. 1989) (right to counsel does not necessarily include meaningful attorney-client relationship); People v. Hodges, 134 P.3d 419, 425-26 (Colo. App. 2005) (cert. granted Apr. 24, 2006) (animosity between defendant and counsel does not require appointment of new counsel); People v. Garcia, 64 P.3d 857 (Colo. App. 2002) (conflict between defendant and counsel amounted to disagreement over strategy, which does not require new counsel). People v. Velasquez, No. 03CA2449, 1-5, 2006 Colo. App. LEXIS 1889 (Colo. App. Nov. 9, 2014 U.S. Dist. LEXIS 14845, *14 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 91 of 106 Page 7 of 21 2006). [*18] As stated above, Applicant bears the burden of proof under § 2254(d).Woodford, 537 U.S. at 25. Applicant fails to demonstrate he is entitled to relief because he fails to identify any clearly established federal law providing that an unconstitutional conflict of interest exists under the circumstances he alleges. In the conflict of interest context, the Supreme Court has noted that it is an open question whether the exception to Strickland for cases of actual conflicts of interest extends to conflicts of interest that do not involve multiple or concurrent representation by counsel. See Mickens, 535 U.S. at 176. Applicant does not allege any conflict of interest premised on either multiple or concurrent representation by counsel and he fails to identify any other clearly established federal law to support his conflict of interest claim. The Court reiterates that clearly established federal law "refers to the holdings, as opposed to the dicta, of [the Supreme] Court's decisions as of the time of the relevant state-court decision." Williams, 529 U.S. at 412. Furthermore, clearly established law consists of Supreme Court holdings in cases where [*19] the facts are at least closely-related or similar to the case sub judice. House, 527 F.3d at 1016. Although the legal rule at issue need not have had its genesis in the closely-related or similar factual context, the Supreme Court must have expressly extended the legal rule to that context. Id. The absence of any clearly established federal law ends the Court's inquiry under § 2254(d)(1).See House, 527 F.3d at 1018. Therefore, the Court finds that Applicant is not entitled to relief on the conflict of interest claim and Claim One will be dismissed for lack of merit. B. Claim Two In this claim, Applicant asserts that the prosecution provided insufficient evidence to support a charge of attempted first degree murder and failed to meet the required burden of proof of intent and after deliberation under Colo. Rev. Stat. § 18-3- 102(1)(a). Application at 6. A habeas applicant's constitutional challenge to the sufficiency of the evidence is governed by Jackson v. Virginia, 443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979).Evidence is sufficient to support a conviction as a matter of due process if, "after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the [*20] essential elements of the crime beyond a reasonable doubt." Id. at 319 (emphasis in the original). A court considers both direct and circumstantial evidence in determining the sufficiency of the evidence. See Lucero v. Kerby, 133 F.3d 1299, 1312 (10th Cir. 1998). The court "may not weigh conflicting evidence nor consider the credibility of witnesses," but must "'accept the jury's resolution of the evidence as long as it is within the bounds of reason.'" Messer v. Roberts, 74 F.3d 1009, 1013 (10th Cir. 1996) (quoting Grubbs v. Hannigan, 982 F.2d 1483, 1487 (10th Cir. 1993)). In applying Jackson, a court looks to state law to determine the substantive elements of the offense. See Jackson, 443 U.S. at 324 n.16; Valdez v. Bravo, 373 F.3d 1093, 1097 (10th Cir. 2004). Under Colorado law, a person is guilty of first degree murder under § 18-3-102(1)(a) when "after deliberation and with the intent to cause the death of a person other than himself, he causes the death of that person or of another person." In addressing this claim, the CCA found as follows. II. Sufficient Evidence of Deliberation Defendant next contends that the evidence was insufficient to support his conviction for attempted first [*21] degree murder. Specifically, he contends that there was insufficient evidence of deliberation. We disagree. A review of a claim of insufficient evidence requires an appellate court to consider whether the evidence adduced at trial could support any rational determination of guilt beyond a reasonable doubt. People v. Frye, 898 P.2d 559, 569 (Colo. 1995).The court is to view the evidence in the light most favorable to the 2014 U.S. Dist. LEXIS 14845, *17 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 92 of 106 Page 8 of 21 prosecution, People v. Bennett, 183 Colo. 125, 132, 515 P.2d 466, 469 (1973), and may not sit as a thirteenth juror and set aside a verdict because it might have drawn a different conclusion from the same evidence. People v. Sprouse, 983 P.2d 771, 778 (Colo. 1999). A person commits first degree murder if "[a]fter deliberation and with the intent to cause the death of a person other than himself [or herself], he [or she] causes the death of that person or of another person." Section 18-3- 102(1)(a), C.R.S. 2006. Thus, to convict a person of attempt to commit first degree murder, the People must prove beyond a reasonable doubt that the defendant acted "after deliberation and with the intent to cause death."See § 18-2-101, C.R.S. 2006 (attempt requires same mental state [*22] as underlying offense). For purposes of first degree murder, "after deliberation" means "not only intentionally but also that the decision to commit the act has been made after the exercise of reflection and judgment concerning the act. An act committed after deliberation is never one which has been committed in a hasty or impulsive manner." Section 18-3-101(3), C.R.S. 2006. Although deliberation requires that a design to kill precede the killing, the time required for deliberation need not be long. People v. Bartowsheski, 661 P.2d 235, 242 (Colo. 1983). Moreover, deliberation must often be proved through circumstantial or indirect evidence. People v. Parsons, 15 P.3d 799, 806 (Colo. App. 2000).Such evidence may include the use of a deadly weapon, see, e.g., People v. Parsons, supra, 15 P.3d at 806; the manner and method of the attempted killing, People v. Webster, 987 P.2d 836, 843 (Colo. App. 1998); and any enmity, hostility, jealousy, or other manifestation of ill will between the accused and the victim, People v. Madson, 638 P.2d 18, 26 (Colo. 1981).Thus, the circumstances surrounding a victim's death may permit a reasonable inference that the defendant was able to deliberate committing [*23] the act before its commission. People v. Parsons, supra, 15 P.3d at 806. Here, the jury could rationally infer that defendant had a premeditated plan to kill the victim using another person's assistance. Specifically, the evidence was that defendant brought a knife with him and began stabbing the victim while sitting behind him on a motorcycle they were riding. The victim testified that defendant began the attack only after a car occupied by someone who was familiar to defendant approached the motorcycle, at which point defendant had asked the victim to slow down. He further testified that this other person assisted defendant in the attack by dragging the victim's body into a ditch after the stabbing. Additionally, the victim testified that during the attack he pleaded with defendant to stop, saying, "Not worth it, you take the bike. You can have the bike. You don't have to do this." He said defendant replied, "Die," or "I'm going to kill you," which he repeated several times. See People v. Madson, supra, 638 P.2d at 26 (deliberation may be inferred from the defendant's hostility towards the victim). Velasquez, No. 03CA2449 at 5-8, 2006 Colo. App. LEXIS 1889. The state court's factual findings, which are presumed [*24] correct in a federal habeas proceeding, are supported by the state court record,Velasquez, No. 02CR2048, Tr. Trans. 7-8- 03 and 7-9-03, and are uncontested by Applicant. The CCA's reliance on People v. Frye, 898 P.2d 559, 569 (Colo. 1995), and People v. Bennett, 183 Colo. 125, 515 P.2d. 466, 469 (1973), is in keeping with the Jackson standard because the CCA, viewing the evidence in a light most favorable to the prosecution, determined that a rational jury could have concluded Applicant had a premeditated plan to kill the victim and acted with deliberation and an intent to cause the victim's death. I, therefore, find the CCA's determination was consistent with federal law because there was sufficient evidence presented at Applicant's trial to support his conviction for attempted murder in the 2014 U.S. Dist. LEXIS 14845, *21 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 93 of 106 Page 9 of 21 first degree. Based on the above findings, the CCA decision regarding Applicant's sufficiency of the evidence claim did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States and did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence [*25] presented in the state court proceeding. This claim, therefore, lacks merit and will be dismissed. C. Claim Four In this claim, Applicant asserts the prosecution failed to establish beyond a reasonable doubt he was the person who committed any of the identified prior offenses that were used to determine he was a habitual criminal. Application at 7. As in Claim Three, Jackson provides the relevant federal law. The CCA addressed this claim as follows: IV. Sufficient Evidence that Defendant was an Habitual Criminal Defendant contends that his adjudication as an habitual offender must be vacated because the prosecution failed to provide sufficient evidence that he is the same Juan Velasquez who received the attempted vehicular eluding conviction. He also argues that the prosecution failed to provide sufficient evidence that the second degree burglary and criminal trespass convictions were separate and distinct criminal episodes. Thus, he claims, the prosecution only proved he was the person convicted of second degree assault, and therefore he did not have the requisite number of prior convictions to establish habitual offender status. We disagree with each of defendant's arguments. As discussed, [*26] a challenge to the sufficiency of the evidence requires a reviewing court to determine whether the relevant evidence, both direct and circumstantial, when viewed as a whole and in the light most favorable to the People, is sufficient to support a conclusion that the defendant is guilty of the crime charged beyond a reasonable doubt. The People must be given the benefit of every reasonable inference that might fairly be drawn from the evidence. People v. Barker, 713 P.2d 406, 407-08 (Colo. App. 1985). To adjudicate a defendant as an habitual criminal, the prosecution must prove beyond a reasonable doubt that the accused is the person named in the prior convictions. People v. Kyle, 111 P.3d 491, 504 (Colo. App. 2004). In habitual criminal proceedings, a duly authenticated copy of the record of former convictions is prima facie evidence of such convictions. Section 18-1.3-802, C.R.S. 2006. Also, "[i]dentification photographs and fingerprints that . . . are part of the records kept . . . by any custodian authorized by the executive director of the department of corrections after sentencing for any such former convictions and judgments, shall be prima facie evidence of identity." Section 18- 1.3-802. [*27] However, to prove exact identity, references to the accused's name and date of birth in the judgment of conviction alone are insufficient. People v. Cooper, 104 P.3d 307, 312 (Colo. App. 2004). Here, the prosecution presented sufficient evidence for a reasonable fact finder to determine beyond a reasonable doubt that defendant is the same Juan Velasquez who was convicted of vehicular eluding. The prosecutor presented defendant's properly authenticated Department of Corrections (DOC) records packet, which contained a copy of the vehicular eluding judgment. It listed defendant's name, birth date, and unique inmate identification number. These are the same name, birth date, and inmate identification number that the DOC case manager who supervised defendant for his second degree assault conviction identified at 2014 U.S. Dist. LEXIS 14845, *24 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 94 of 106 Page 10 of 21 trial as belonging to defendant. The DOC case manager also made an in court identification of defendant as the same Juan Velasquez whose identifying information is contained in the judgment for vehicular eluding. Moreover, the name, birth date, and inmate identification number listed in the vehicular eluding judgment are also listed on three properly authenticated photographs of [*28] defendant contained in his DOC records packet and on the three properly authenticated fingerprint cards belonging to defendant that are contained in his DOC records packet. Additionally, we note that the case number for the vehicular eluding conviction (1999CR1735) was imbedded in a number listed on the most recent fingerprint card (D0011999CR001735). Thus, contrary to defendant's argument, it is of no consequence that the three authenticated DOC photographs and three fingerprint cards did not list the vehicular eluding charge or conviction by name. See People v. Kyle, supra, 111 P.3d at 505 (holding evidence sufficient where non-DOC arrest fingerprints, identified as defendant's, listed defendant's date of birth);People v. Cooper, supra, 104 P.3d at 310-12 (evidence sufficient where supervising probation office made an in court identification of defendant as same individual listed on documents containing case numbers of previous convictions); People v. Carrasco, 85 P.3d 580, 583 (Colo. App. 2003) (evidence sufficient where defendant's arrest record identified him by unique Denver Police Department (DPD) number and referenced prior convictions by case number, and DPD officer testified [*29] defendant's fingerprints matched those on file for same DPD number); People v. Benton, 829 P.2d 451, 454 (Colo. App. 1991) (holding evidence of 1982 conviction sufficient without conviction specific fingerprints because defendant's unique inmate identification number was listed on photographs and fingerprint cards made during prior incarcerations). We also disagree with defendant's contention that the prosecution failed to prove beyond a reasonable doubt that his convictions for first degree criminal trespass and second degree burglary were separate and distinct criminal episodes. Defendant argues that the fact that the convictions were entered on the same date does not indicate that the two convictions were separate and distinct episodes, and that the only pieces of evidence offered to show that the offenses occurred on separate dates were the judgments of conviction, which, according to defendant, were insufficiently linked to him. However, contrary to defendant's assertion, these properly authenticated documents were adequately linked to him because they include his name, date of birth, and (despite defendant's incorrect assertion to the contrary) his unique inmate identification [*30] number. Furthermore, both judgments of conviction directly reference an identification photograph and fingerprint card in defendant's authenticated DOC records packet. See People v. Bernabei, 979 P.2d 26, 31 (Colo. App. 1998) (inferring two felonies were separately brought and tried when document stated that the felonies were committed on separate dates). Velasquez, No. 03CA2449 at 11-16, 2006 Colo. App. LEXIS 1889. The state court's factual findings, which are presumed correct in a federal habeas proceeding, are supported by the state court record, Velasquez, No. 02CR2048, Nov. 4, 2003 Sentencing Hr'g, and are uncontested by Applicant. The CCA's reliance on People v. Barker, 713 P.2d 406, 407-08 (Colo. App. 1985), and People v. Kyle, 111 P.3d 491, 504 (Colo App. 2004), is in keeping with the Jackson standard because the CCA, viewing the evidence in a light most favorable to the prosecution, determined a conclusion that Applicant beyond a reasonable doubt was the same individual who had committed the crimes in the prior convictions. The Court therefore finds the CCA's determination that there was sufficient evidence presented at Applicant's sentencing hearing to support an habitual criminal adjudication was consistent [*31] with federal law. Based on the above findings, the CCA decision 2014 U.S. Dist. LEXIS 14845, *27 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 95 of 106 Page 11 of 21 regarding Applicant's sufficiency of the evidence claim did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States and did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. This claim, therefore, lacks merit and will be dismissed. D. Claim Five In this claim, Applicant asserts that his ninety-six year sentence is disproportionate to the offense he committed. Application at 7. "The Eighth Amendment, which forbids cruel and unusual punishments, contains a 'narrow proportionality principle' that 'applies to noncapital sentences.'" Ewing v. California, 538 U.S. 11, 20, 123 S. Ct. 1179, 155 L. Ed. 2d 108 (2003) (quoting Harmelin v. Michigan, 501 U.S. 957, 996-97, 111 S. Ct. 2680, 115 L. Ed. 2d 836 (1991) (Kennedy, J., concurring in part and concurring in judgment)). A sentence violates the Eighth Amendment if it is "grossly disproportionate to the severity of the crime." Although the Supreme Court has admitted there is a lack of clarity regarding what factors may indicate gross [*32] disproportionality, the Court has acknowledged that a "gross disproportionality principle is applicable to sentences for terms of years," and "the gross disproportionality principle reserves a constitutional violation for only the extraordinary case." See Lockyer v. Andrade, 538 U.S. 63, 72, 123 S. Ct. 1166, 155 L. Ed. 2d 144 and 77 (2003). The Supreme Court has only twice invalidated a sentence under the Eighth Amendment. See Weems v. United States, 217 U.S. 349, 30 S. Ct. 544, 54 L. Ed. 793 (1910) (defendant sentenced to fifteen years in chains and hard labor for falsifying a public document); Solem v. Helm, 463 U.S. 277, 103 S. Ct. 3001, 77 L. Ed. 2d 637 (1983) (defendant sentenced to life without parole after committing six nonviolent felonies including writing a bad $100-dollar check). Gross proportionality cases also are inherently fact-specific.See e.g. Rummel v. Estelle, 445 U.S. 263, 265-66, 275-76, 100 S. Ct. 1133, 63 L. Ed. 2d 382 (1980) (concluding that sentence of life imprisonment with possibility of parole imposed under state recidivist statute did not violate Eighth Amendment, where defendant had two previous felony convictions—one for "fraudulent use of a credit card to obtain $80 in goods or services" and another for "passing a forged check in the amount of $28.36"—and was then convicted of felony [*33] theft for "obtaining $120.75 by false pretenses"); Hutto v. Davis, 454 U.S. 370, 102 S. Ct. 703, 70 L. Ed. 2d 556 (1982) (upholding against a proportionality attack a sentence of 40 years' imprisonment for possession with intent to distribute nine ounces of marijuana); Harmelin, 501 U.S. 957, 994, 111 S. Ct. 2680, 115 L. Ed. 2d 836 (1991) (plurality opinion holding that sentence of life imprisonment without parole for first-time offender's possession of 672 grams of cocaine did not violate the Eighth Amendment);Ewing, 538 U.S. at 30-31 (upholding against a proportionality attack a twenty-five year to life sentence imposed under a California recidivist statute for the offense of felony grand theft (i.e., stealing three golf clubs worth approximately $1,200); Lockyer, 538 U.S. at 77 (upholding on federal habeas review the state appellate court's determination that two consecutive twenty-five-year to life sentences imposed under a state recidivist statute for two counts of petty theft did not violate clearly established Supreme Court Eighth Amendment jurisprudence). In Solem, the Supreme Court instructed the lower courts to consider the following three criteria in analyzing proportionality claims under the Eighth Amendment: "(I) the gravity of the offense [*34] and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions." Solem, 463 U.S. at 292. The Supreme Court revisited the proportionality issue in Harmelin. In a fractured opinion, Justice Kennedy, joined by Justices O'Connor and Souter, wrote separately to argue for the existence of a 2014 U.S. Dist. LEXIS 14845, *31 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 96 of 106 Page 12 of 21 narrow proportionality guarantee. Harmelin, 501 U.S. at 996 (Kennedy, J., concurring in part and concurring in the judgment). In reviewing the three- part test articulated by the Court in Solemn, Justice Kennedy stated: Solem is best understood as holding that comparative analysis within and between jurisdictions is not always relevant to proportionality review . . . . A better reading of our cases leads to the conclusion that intrajurisdictional and interjurisdictional analyses are appropriate only in the rare case in which a threshold comparison of the crime committed and the sentence imposed leads to an inference of gross disproportionality . . . . The proper role for comparative analysis of sentences, then, is to validate an initial judgment that a sentence is grossly disproportionate [*35] to a crime. Id. at 1004-05. The United States Court of Appeals for the Tenth Circuit has determined that "Justice Kennedy's opinion in Harmelin narrows Solem and sets forth the applicable Eighth Amendment proportionality test." Hawkins v. Hargett, 200 F.3d 1279, 1282 (10th 1999). The CCA conducted an abbreviated proportionality review of Applicant's sentence and evaluated (1) the gravity of the crime and (2) the harshness of the penalty, relying on People v. Gaskins, 825 P.2d 30, 38 (Colo. 1992) (case relies on Harmelin and Solem). The CCA rejected Applicant's claim that his sentence was grossly disproportionate to his crime based on the following reasoning: VI. Sentence Proportionality Defendant next contends that the trial court violated his Eighth Amendment rights by failing to conduct an extended proportionality review. We disagree. Based on defendant's status as an habitual offender, the trial court imposed the statutorily required sentence of ninety-six years. The court then conducted a proportionality review. Finding no inference of gross disproportionality, the court concluded that, although defendant's lengthy criminal history consisted of nonviolent offenses, his conviction in [*36] this case was for an extremely violent crime. Defendant contends that he was entitled to an extended proportionality review because his prior offenses were not grave and serious. He further argues that, had such an extended review been conducted, his sentence would prove grossly disproportionate in violation of the constitutional guarantee against cruel and unusual punishment. We disagree. Sentence proportionality is a question of law subject to de novo review. People v. McNally, 143 P.3d 1062 (Colo. App. 2005). An extended proportionality review is only necessary when the crimes supporting the habitual sentence are not grave or serious or when the defendant is sentenced to life with no possibility for parole. See People v. Gaskins, 825 P.2d 30, 37 (Colo. 1992).The gravity or seriousness of a crime is determined by considering the harm caused or threatened to the victim or to society and the culpability of the offender. People v. Deroulet, 48 P.3d 520, 524 (Colo. 2002).However, some crimes are so inherently grave and serious that they are per se considered facially grave and serious; crimes involving violence or the potential for violence are included in this category. [*37] See People v. Gaskins, supra, 825 P.2d at 37. When only an abbreviated proportionality review is needed, an appellate court is well positioned to conduct the review because there is no need to inquire into the details of the specific offenses or conduct a detailed comparison of sentences. See People v. Gaskins, supra, 825 P.2d at 38.An abbreviated review consists simply of a scrutiny of the crimes supporting the habitual criminal sentence to determine whether in combination they are so lacking in gravity or seriousness as to suggest that the sentence is constitutionally disproportionate. People v. 2014 U.S. Dist. LEXIS 14845, *34 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 97 of 106 Page 13 of 21 Gaskins, supra, 825 P.2d at 37. Here, the triggering offenses of attempted first degree murder, first degree assault, and a crime of violence deadly weapon and serious bodily injury were all inherently violent in nature and, thus, grave and serious. See People v. Deroulet, supra, 48 P.3d at 524 (accessory to first degree murder is inherently grave and serious); People v. Smith, 848 P.2d 365, 374 (Colo. 1993) (defining first degree murder as a "crime of the utmost gravity"); People v. Penrod, 892 P.2d 383, 387 (Colo. App. 1994) (concluding first degree assault and attempted second degree murder [*38] unquestionably grave and serious). Furthermore, all but one of defendant's prior offenses were grave and serious. See Alvarez v. People, 797 P.2d 37, 41-42 (Colo. 1990) (first degree criminal trespass is grave and serious); People v. McNally, supra, 143 P.3d at 1064 (second degree burglary is grave and serious); People v. Allen, 111 P.3d 518, 520 (Colo. App. 2004) (vehicular eluding is grave and serious). Moreover, defendant's sentences were concurrent and subject to parole, as well as earned time reduction. Thus, although one of defendant's prior offenses was not grave and serious, in combination the gravity and seriousness of his crimes do not suggest that his statutorily mandated ninety-six-year sentence was grossly disproportionate. No further proportionality review is required. See, e.g.,Alvarez v. People, supra, 797 P.2d at 41 (no further review necessary when there is no inference of disproportionality). Velasquez, No. 03CA2449 at 17-20, 2006 Colo. App. LEXIS 1889. As stated above, the law is clearly established that a gross disproportionality principle is applicable to sentences for terms of years. Lockyer, 538 U.S. at 72.For purposes of federal habeas review of a proportionality decision, however, there [*39] is a lack of "clear objective standards to distinguish between sentences for different terms of years." Harmelin, 501 U.S. at 1001.The more general the rule the more leeway courts have in case-by-case determinations. Richter, 131 S. Ct. at 786. The CCA addressed the gravity of Applicant's offense and the harshness of the penalty imposed that are factors relevant to the gross proportionality determination under Supreme Court case law. See Ewing, 538 U.S. 22 (directing the courts to review the gravity of the offense to determine if it matches the severity of the punishment); Solem, 463 U.S. at 291-92;Harmelin, 501 U.S. at 1002-1004 (Kenney, J., concurring in part and concurring in the judgment) (comparing the gravity of the petitioner's offense to the sentence of life imprisonment without parole). The CCA's determination that the offense of attempted first degree murder, first degree assault, and a crime of violence with the use of a deadly weapon and serious bodily injury is a grave and serious crime under Colorado law is not subject to challenge in this federal habeas proceeding. See Estelle v. McGuire, 502 U.S. 62, 67-68, 112 S. Ct. 475, 116 L. Ed. 2d 385 (1991) ("[I]t is not the province of a federal habeas court [*40] to reexamine state-court determinations on state-law questions."). Moreover, the CCA made a reasonable determination that Applicant's sentence was not so harsh as to give rise to an inference of gross disproportionality based on factual findings which are presumed correct in this federal habeas proceeding and are supported by the state court record. Applicant does not point to any clear and convincing evidence to the contrary. In addition, Applicant's sentence was statutorily mandated. This Court is reluctant to interfere with the legislative determination of an appropriate sentence range. See Rummel, 445 U.S. at 275-76 (concluding that length of prison sentences for serious felonies is "properly within the province of legislatures, not courts"); Harmelin, 501 U.S. at 998 (same) (citing Rummel). Applicant's sentence also provides opportunity for parole and earned time reduction. See Rummel, 445 U.S. at 280-81 (finding it significant that the defendant had the possibility of parole, and concluded that the possibility of parole, however unlikely, distinguished the defendant from someone serving a life sentence without parole). And, finally, 2014 U.S. Dist. LEXIS 14845, *37 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 98 of 106 Page 14 of 21 Applicant's circumstances do not differ significantly [*41] from those in cases where the Supreme Court has rejected Eighth Amendment proportionality challenges. See, e.g., Harmelin, 501 U.S. at 994;Hutto, 454 U.S. at 375. A constitutional violation based on the gross proportionality principle is reserved for "only the extraordinary case." Lockyer, 538 U.S. at 77. Furthermore, the CCA's decision was not "so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement." Richter, 131 S. Ct. at 786-87. Based on the above findings, the CCA decision regarding Applicant's proportionality claim did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States and did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. This claim, therefore, lacks merit and will be dismissed. E. Claim Six In this claim, Applicant asserts prosecutorial misconduct took place during closing and rebuttal argument because the prosecution (1) misstated the law concerning the [*42] requisite mens rea necessary for a conviction of an attempted first degree murder charge; and (2) stated that he believed Applicant was guilty and the jury need to convict Applicant to protect society. Application at 7. Habeas relief is available for prosecutorial misconduct only when the misconduct is so egregious that it renders the entire trial fundamentally unfair. See Donnelly v. DeChristoforo, 416 U.S. 637, 645-48, 94 S. Ct. 1868, 40 L. Ed. 2d 431 (1974).In order to determine whether prosecutorial misconduct rendered the trial fundamentally unfair, the Court must consider "the totality of the circumstances, evaluating the prosecutor's conduct in the context of the whole trial." See Jackson v. Shanks, 143 F.3d 1313, 1322 (10th Cir. 1998).The prosecution is forbidden from deliberately deceiving the court and jury. See Gray v. Netherland, 518 U.S. 152, 165, 116 S. Ct. 2074, 135 L. Ed. 2d 457 (1996). Applicant bears the burden of establishing a claim of deception, which the Court reviews de novo. See Foster v. Ward, 182 F.3d 1177, 1191-92 (10th Cir. 1999). "Inappropriate prosecutorial comments, standing alone, would not justify a reviewing court to reverse a criminal conviction obtained in an otherwise fair proceeding." United States v. Young, 470 U.S. 1, 11, 105 S. Ct. 1038, 84 L. Ed. 2d 1 (1985). [*43] The courts must "consider the probable effect the prosecutor's [statements] would have on the jury's ability to judge the evidence fairly." Tillman v. Cook, 215 F.3d 1116, 1129 (10th Cir. 2000) (quoting Moore v. Reynolds, 153 F.3d 1086, 1113 (10th Cir. 1998),cert. denied,526 U.S. 1025, 119 S. Ct. 1266, 143 L. Ed. 2d 362 (1999)). The federal habeas court does not consider a prosecutor's statement or argument "word by word in a vacuum." Paxton v. Ward, 199 F.3d 1197, 1217 (10th Cir. 1999). In making this assessment, a court should examine whether "the prosecutor's argument . . . manipulate[d] or misstate[d]" the evidence, whether "it implicate[d] other specific rights of the accused such as the right to counsel or the right to remain silent," whether "the objectionable content was invited by or responsive to the opening summation of the defense," and whether "[t]he weight of the evidence against applicant was heavy." Darden v. Wainwright, 477 U.S. 168, 181-82, 106 S. Ct. 2464, 91 L. Ed. 2d 144 (1986)."Any cautionary steps-such as instructions to the jury-offered by the court to counteract improper remarks," are also relevant. Bland v. Sirmons, 459 F.3d 999, 1024 (10th Cir. 2006) (alteration in original) (internal quotation marks and citation omitted). [*44] "Inquiry into fundamental fairness requires examination of the entire proceedings," and "[c]ounsel's failure to object to the comments, while not dispositive, is also relevant to a fundamental fairness assessment." Le v. Mullin, 311 F.3d 1002, 1013 (10th Cir. 2002) (citations omitted and emphasis added). 2014 U.S. Dist. LEXIS 14845, *40 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 99 of 106 Page 15 of 21 "[I]t is not enough that the prosecutors' remarks were undesirable or even universally condemned." Darden, 477 U.S. at 181 (internal quotation marks omitted). Rather, "[t]he ultimate question is whether the jury was able to fairly judge the evidence in light of the prosecutors' conduct." Bland, 459 F.3d at 1024. In addressing this claim, the CCA found as follows: V. Prosecutor's Closing Arguments Although defendant did not object at trial, he now contends that two instances of prosecutorial misconduct during closing and rebuttal closing argument require reversal. We disagree that either comment, or the cumulative effect of both, constitutes plain error. Allegations of prosecutorial misconduct not objected to at trial are reviewed for plain error, which occurs only when the prosecutor's actions are flagrant or glaringly or egregiously improper, and undermine the fundamental fairness of the [*45] trial so as to cast serious doubt on the reliability of the conviction. People v. Wallace, 97 P.3d 262, 268-69 (Colo. App. 2004). Defendant argues that when the prosecutor told the jury that defendant's statement, "I'm going to kill you," constituted deliberation, he misstated the law regarding the requisite mental state for the attempt element of the crime of attempted first degree murder. However, the jury was properly instructed on the element of deliberation, and, properly considered in context, this comment was merely argument by the People that defendant's statements and inferences legitimately drawn therefrom were sufficient to prove the element of deliberation. Nor did the People's request to the jury to hold defendant "accountable" constitute plain error. Even if improper, the prejudicial effect of the comment was negligible and did not cast doubt upon the reliability of his conviction. Velasquez, No. 03CA2449 at 16-17, 2006 Colo. App. LEXIS 1889. A review of the trial court's alleged error is subject to the plain error test. Colorado's plain error test is rooted in due process. See People v. Kruse, 839 P.2d 1, 3 (Colo. 1992) ("Plain error occurs when . . . the error so undermined the fundamental fairness [*46] of the trial itself as to cast serious doubt on the reliability of the judgment of conviction.") (internal quotation marks omitted). Because there is no practical distinction between Colorado's plain error test and the federal due process test that requires reversal when error "so infused the trial with unfairness as to deny due process of law," Estelle, 502 U.S. at 75 (internal quotation marks and citation omitted), the deferential standard of review applies unless the CCA unreasonably applied federal due process law, see Thornburg v. Mullin, 422 F.3d 1113, 1124-25 (10th Cir. 2005) (citing 28 U.S.C. § 2254(d)). The trial court instructed each of the jurors that the closing arguments are not evidence and they are to determine the facts of the case based solely on the evidence. July 7, 2003 Trial Tr. at 151-52. Jurors are presumed to follow the instructions given and give less weight to counsel's arguments. See Weeks v. Angelone, 528 U.S. 225, 234, 120 S. Ct. 727, 145 L. Ed. 2d 727 (2000);Boyde v. California, 494 U.S. 370, 384, 110 S. Ct. 1190, 108 L. Ed. 2d 316 (1990) (explaining that "arguments of counsel generally carry less weight with a jury than do instructions from the court"). The Court also has reviewed the trial court's instruction on deliberation [*47] and finds the instruction was proper. July 9, 2003 Trial Tr. at 56-57. Even if the prosecutors' comments were improper, they did not infuse the trial with unfairness and result in a denial of due process of law. The comments were fleeting, based on argument not evidence, and do not provide a basis for finding the jury was unable to fairly judge the evidence in light of the prosecutors' conduct. The CCA decision regarding this claim, therefore, did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States and did not result in a decision 2014 U.S. Dist. LEXIS 14845, *44 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 100 of 106 Page 16 of 21 that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. Claim Six, therefore, fails to assert a claim for federal habeas relief and is dismissed for lack of merit. F. Claim Seven In this Claim, Applicant sets forth five claims of ineffective assistance of trial counsel. Application at 7-8. It was clearly established when Applicant was convicted that a defendant has a right to effective assistance of counsel. See Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984).To establish [*48] that counsel was ineffective, Applicant must demonstrate both that counsel's performance fell below an objective standard of reasonableness and that counsel's deficient performance resulted in prejudice to his defense. See id. at 687. "Judicial scrutiny of counsel's performance must be highly deferential." Id. at 689. There is a "strong presumption" that counsel's performance falls within the range of "reasonable professional assistance." Id. It is an applicant's burden to overcome this presumption by showing that the alleged errors were not sound strategy under the circumstances. See id. Under the prejudice prong, an applicant must establish "a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different." Strickland, 466 U.S. at 694."A reasonable probability is a probability sufficient to undermine confidence in the outcome." Id. In assessing prejudice under Strickland the question is whether it is reasonably likely the result would have been different. Harrington v. Richter, 131 S. Ct. at 791. "The likelihood of a different result must be substantial, not just conceivable." Id. at 792 (citing Strickland, 466 U.S. at 693.) Furthermore, [*49] under AEDPA, "[t]he pivotal question is whether the state court's application of the Strickland standard was unreasonable. This is different from asking whether defense counsel's performance fell below Strickland's standard," which is the question asked if the claim came to the court "on direct review of a criminal conviction in a United States district court." Richter, 131 S. Ct. at 785. "When § 2254(d) applies, the question is not whether counsel's actions were reasonable. The question is "whether there is any reasonable argument that counsel satisfied Strickland's deferential standard." Id. at 788. If Applicant fails to satisfy either prong of the Strickland test, the ineffective assistance of counsel claim must be dismissed. See id. at 697. Also, ineffective assistance of counsel claims are mixed questions of law and fact. Id. at 698. The Court will address each of the five ineffective assistance claims as follows. 1. Coercion to not testify In the Court's February 1, 2013 Order, Respondents were directed to brief the substantialness of this claim under Martinez v. Ryan, 132 S. Ct. 1309, 1312, 182 L. Ed. 2d 272 (2012). Although Applicant raised a Martinez issue in his Reply to the Pre-Answer Response [*50] regarding this claim, asserting a basis for procedural default of the claim, he has not replied to Respondents' briefing on the substantialness of the claim. In Martinez, the U.S. Supreme Court held that a "procedural default will not bar a federal habeas court from hearing a substantial claim of ineffective assistance at trial if, in the [State's] initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective." Martinez, 132 S. Ct. at 1320.The narrow exception in Martinez to find cause for excusing such a default is based on if (1) the ineffective-assistance-of-trial-counsel claim was a "substantial" claim; (2) the "cause" consisted of there being "no counsel" or only "ineffective" counsel during the state collateral review proceeding; (3) the state collateral review proceeding was the "initial" review proceeding in respect to the "ineffective- assistance-of-trial-counsel claim"; and (4) state 2014 U.S. Dist. LEXIS 14845, *47 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 101 of 106 Page 17 of 21 law requires that the claim "be raised in an initial-review collateral proceeding." Trevino v. Thaler, 133 S. Ct. 1911, 1913, 185 L. Ed. 2d 1044 (2013) (quoting Martinez, 132 S. Ct. at 1320.) (internal quotation marks omitted). Respondents assert the trial court gave Applicant [*51] a People v. Curtis, 681 P.2d 504 (Colo. 1984), advisement instructing Applicant that he had the right to testify or not to testify, that if he chose to remain silent the jury could not use that decision against him, and that he should discuss the decision with trial counsel, but the decision was his personal decision to make. Respondents further assert Applicant told the trial court that he had chosen not to testify and had made the decision freely and voluntarily. A review of the trial court transcript indeed shows that Applicant was given a Curtis instruction and he freely and voluntarily chose not to testify. July 9, 2003 Trial Tr. at 25-28. Based on these findings, Respondents conclude that Applicant's claim is without factual support in the record and is insubstantial. Therefore, Applicant has failed to show cause for the default of this claim based on Martinez. This claim will be dismissed as procedurally barred from federal habeas review. 2. Failure to raise affirmative defense of voluntary intoxication/Failure to conduct reasonable investigation and interview witnesses to support voluntary intoxication defense The CCA addressed these issues as follows: An attorney has a duty to [*52] investigate possible defenses or make reasonable determinations not to pursue them. See People v. Bergerud, 223 P.3d 686, 705 (Colo. 2010). A decision not to investigate certain witnesses does not amount to ineffective assistance of counsel if it is made in the exercise of reasonable professional judgment. See People v. Apodaca, 998 P.2d 25, 29 (Colo. App. 1999). A defendant may present a voluntary intoxication defense to negate the existence of the specific intent element of the crime charged. See § 18-1-804(1), C.R.S. 2011. However, pursuing such a defense may be inconsistent with or may potentially undermine a defendant's theory of defense. See People v. Villarreal, 131 P.3d 1119, 1125 (Colo. App. 2005) (where the defendant's defense was that she was not the person who attacked the victim, "[p]roviding the jury with an intoxication instruction would have been inconsistent with, and potentially undermining of, her theory of defense"). Here, the postconviction court found that: • Trial counsel knew about the intoxication defense and understood the nature of that defense; • Trial counsel explored with defendant "the collateral consequences of pursuing that defense in terms of diminishing [*53] other potential defenses," including self-defense; • Trial counsel made an informed decision "after investigation had been completed, an investigator had been utilized, numerous witnesses had been interviewed, and discovery had been reviewed"; and • Trial counsel's decision "was a thoughtful decision made by [him] at the time, after reviewing the evidence, and the legal options available to him, and understanding that the. . . voluntary intoxication defense had limited utility" based on "his experience in hundreds of cases" and could have adversely impacted defendant's pursuit of other defenses. The court's findings are supported by the record. At the Crim. P. 35(c) hearing, trial counsel testified that: • He had tried more than 300 cases and had dealt with the potential defense of voluntary intoxication many times and the ramifications and subtleties involved with presenting the defense; • In his experience, a defendant did not "fare[] well" with intoxication as a defense, even in cases where he put on an expert 2014 U.S. Dist. LEXIS 14845, *50 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 102 of 106 Page 18 of 21 witness who could testify about the defendant's blood alcohol level; • In this case, there was no blood alcohol test to rely upon; • Putting on evidence of defendant's intoxication [*54] would have opened the door to other bad character evidence; • Although trial counsel could not recall exactly why he recommended not to pursue an intoxication defense, he testified that he made the decision and recommended it to defendant, and defendant agreed with the decision; • The decision was made after he obtained discovery, interviewed witnesses, and was advised by defendant of "what he would have been consuming that day"; and • At trial, he attempted to implicate codefendant in the crime. It further appears that trial counsel made a reasonable determination not to interview the witness who supposedly could testify to the quantity of alcohol defendant consumed, once the decision had been made not to pursue the defense of voluntary intoxication. We defer to the postconviction court's findings because they are supported by the record. See Kyler, 991 P.2d at 818. The court's findings support a conclusion that trial counsel made a reasonable and informed strategic decision to forgo the voluntary intoxication defense, he explained the decision to defendant, and defendant agreed with the decision at the time it was made. Trial counsel reviewed discovery, interviewed witnesses, and knew [*55] that defendant had consumed a substantial amount of alcohol that day. He then relied on his experience of pursuing the intoxication defense in other cases in making a reasonable strategic decision not to pursue it in defendant's case. While counsel did not interview the potential witness who may have been able to confirm the amount of alcohol defendant had consumed, defendant had told trial counsel what he had drunk and what that witness would likely say. Although trial counsel testified that "[they] did not think [they] would have sufficient evidence to convince a jury regarding intoxication," that statement, alone, does not support a conclusion that trial counsel's decision not to interview the witness constituted deficient performance. Rather, the record as a whole shows that trial counsel relied on (1) his experience that intoxication defenses did not do well even when an expert witness testified about the defendant's blood alcohol level, and (2) the fact that there was no blood alcohol test to rely on in this case. Therefore, we agree with the postconviction court that trial counsel's decision was made with the reasonable understanding that the "voluntary intoxication defense had [*56] limited utility." Further, while counsel did not pursue a self- defense theory at trial, the failure to do so was due to defendant's own conduct. Trial counsel also attempted to implicate codefendant in the crime, which would have been inconsistent with an intoxication defense. See Villarreal, 131 P.3d at 1125.Under these circumstances, we conclude that the postconviction court properly determined that trial counsel's performance was not deficient. Based on our conclusion that trial counsel was not deficient, we need not review defendant's argument that trial counsel's performance prejudiced his defense. See Karpierz, 165 P.3d at 759. People v. Velasquez, No. 11CA0450, 5-10, 2012 Colo. App. LEXIS 960 (Colo. App. June 14, 2012). "The duty to investigate derives from counsel's basic function . . . to make the adversarial testing process work in the particular case." Williamson v. Ward, 110 F.3d 1508, 1514 (10th Cir. 1997) (internal quotation marks omitted). "[C]ounsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations unnecessary." Id. (internal quotation marks omitted). "[S]trategic choices made after less than complete investigation are reasonable precisely [*57] to the extent that reasonable professional judgments support the limitations on 2014 U.S. Dist. LEXIS 14845, *53 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 103 of 106 Page 19 of 21 investigation. In other words, counsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations unnecessary." Strickland, 466 U.S. at 690-91. Even if trial counsel was ineffective in not conducting a reasonable investigation and interviewing witnesses that would support a voluntary intoxication defense, Applicant fails to assert how he was prejudiced by trial counsel's conduct. Applicant does not assert what trial counsel would have discovered if he had investigated and interviewed witnesses that would support a voluntary intoxication defense. Moreover, in light of the evidence presented in the state court proceedings, the CCA's determination was reasonable. As a result of the evidentiary hearing held by the Rule 35(c) court, the trial court found that trial counsel reviewed discovery, interviewed witnesses, knew that Applicant had consumed a substantial amount of alcohol, and relied on his experience in pursuing the intoxication defense in other cases in making his strategic decision not to pursue this defense in Applicant's case. The factual findings [*58] relied on by the trial court are presumed correct in this federal habeas proceeding and are supported by the state court record. Feb. 11, 2011 Hr'g Tr. At 1-64. Because Applicant does not point to any clear and convincing evidence to the contrary, I find that Applicant has not demonstrated a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different." Strickland, 466 U.S. at 694. Based on the above findings, the CCA decision regarding Applicant's investigation and interview claim did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States and did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. This claim, therefore, lacks merit and will be dismissed. 3. Failure to object to prosecution's misstatements of law and misconduct in closing and rebuttal arguments Applicant asserts that trial counsel was ineffective for not objecting to the prosecution's closing remarks, which prevented review under the lesser [*59] standard of harmless error rather than plain error on direct appeal. The CCA addressed this issue as follows: 3. Failure to Object to Prosecutor's Closing Velasquez also contends that counsel's performance at trial was deficient because he failed to object to certain statements by the prosecution during closing argument. Specifically, Velasquez argues that the prosecution misstated the law by telling the jury Velasquez's alleged statement to the victim, "I'm going to kill you," was sufficient to show he acted after deliberation and that the prosecutor improperly interjected his personal opinion when he urged the jury to hold Velasquez accountable for the victim's injuries. We note that on direct appeal Velasquez argued that these same remarks were improper and required reversal of his convictions. Since his trial counsel did not object, the panel reviewed these remarks under the plain error standard. The panel found the jury was properly instructed on the element of deliberation and it was not improper for the prosecution to argue that the jury could infer from such a statement that Velasquez acted with the requisite deliberation. In addition, the panel found that even if it were improper [*60] for the prosecution to tell the jury Velasquez should be held accountable for his actions, any prejudicial effect from the comment was minimal. Velasquez now renews these arguments in the context of a claim of ineffective assistance of counsel. Even if we assume that counsel should have objected to these remarks, to satisfy the second prong of Strickland Velasquez must show that such objection 2014 U.S. Dist. LEXIS 14845, *57 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 104 of 106 Page 20 of 21 would have created a reasonable probability that the outcome of the trial would have been different. We conclude on the trial record this prong is not met. We agree with the panel's statement in Velasquez's direct appeal: the jury was properly instructed on deliberation and could properly infer deliberation from his remark, and the reference to holding him accountable had a minimal prejudicial effect, if any. Velasquez, No. 07CA1796 at 8-9, 2009 Colo. App. LEXIS 61. Applicant does not specify in the Application what remarks trial counsel should have challenged. In his postconviction motion he asserted ineffective assistance of counsel because trial counsel failed to object to the same remarks he challenged in his direct appeal as improper. As I stated above, the comments were fleeting, based on argument not evidence, and [*61] do not provide a basis for finding the jury was unable to fairly judge the evidence in light of the prosecutors' conduct. Therefore, I find that Applicant was not prejudiced by these remarks. Based on the above findings, the CCA decision regarding Applicant's closing remarks claim did not result in a decision that was contrary to, or involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States and did not result in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the state court proceeding. This claim, therefore, lacks merit and will be dismissed. 4. Cumulative error The cumulative error doctrine applies only when there are two or more actual errors, and it does not apply to the accumulation of non-errors. Castro v. Ward, 138 F.3d 810, 832 (10th Cir. 1998). On federal habeas review, a cumulative error analysis applies only to cumulative constitutional errors. Young v. Sirmons, 551 F.3d 942, 972 (10th Cir. 2008). Since none of the ineffective assistance claims have been found to state a constitutional error, the cumulative error claim will be dismissed for lack [*62] of merit. G. Claim Eight In this claim, Applicant asserts that he was denied his right to a jury trial on the habitual criminal counts in violation of Apprendi v. New Jersey, 530 U.S. 466, 120 S. Ct. 2348, 147 L. Ed. 2d 435 (2000). Application at 8. The Court will dismiss this claim for lack of merit. Apprendi clearly exempts judicial factfinding regarding prior convictions from the rule that only a jury may constitutionally find facts which increase a defendant's maximum sentence. United States v. Moore, 401 F.3d 1220, 1223-24 (10th Cir. 2005);see also United States v. Delacruz-Soto, 414 F.3d 1158, 1164 n. 2 (10th Cir. 2005) (noting that Almendarez-Torres, 523 U.S. 224, 118 S. Ct. 1219, 140 L. Ed. 2d 350 (1998), forecloses argument that a jury, not the sentencing court, must find that defendant had prior convictions). Even though the recidivism exception announced in Almendarez-Torres, has been eroded, the Supreme Court has not overruled the exception. See Moore, 401 F.3d at 1224. IV. Conclusion For the foregoing reasons, it is ORDERED that the Application for a Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2254, ECF No. 6, is DENIED. It is FURTHER ORDERED that I sua sponte deny the issuance of a Certificate of Appealability pursuant to 28 U.S.C. § 2253(a). [*63] Having considered the standards of Slack v. McDaniel, 529 U.S. 473, 484, 120 S. Ct. 1595, 146 L. Ed. 2d 542 (2000), I find that Applicant has not made a substantial showing of the denial of a constitutional right such that reasonable jurists could disagree as to the disposition of his petition. 28 U.S.C. § 2253(c)(2). It is FURTHER ORDERED that I also sua sponte certify pursuant to 28 U.S.C. § 1915(a)(3) that any appeal from this Order is not taken in good faith, 2014 U.S. Dist. LEXIS 14845, *60 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 105 of 106 Page 21 of 21 and, therefore, in forma pauperis status will be denied for the purpose of appeal. See Coppedge v. United States, 369 U.S. 438, 82 S. Ct. 917, 8 L. Ed. 2d 21 (1962). If Applicant files a notice of appeal he must also pay the full $505.00 appellate filing fee or file a motion to proceed in forma pauperis in the United States Court of Appeals for the Tenth Circuit within thirty days in accordance with Fed. R. App. P. 24. Dated: February 5, 2014. BY THE COURT: /s/ Wiley Y. Daniel WILEY Y. DANIEL, SENIOR UNITED STATES DISTRICT JUDGE End of Document 2014 U.S. Dist. LEXIS 14845, *63 Case 1:21-cv-02306-RM-KLM Document 30-1 Filed 10/08/21 USDC Colorado Page 106 of 106