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Sanders v. City of Hodgenville

United States District Court, W.D. Kentucky, Louisville Division

March 28, 2018



          David J. Hale, Judge

         Plaintiff Deeann Sanders initiated a late-night encounter with police officers at the scene of her husband's DUI arrest, which was very near her home in Hodgenville, Kentucky. (See Docket No. 1-2) A police car dashcam recorded the incident, and police later released the video to the media. (See id.) Sanders sued the City of Hodgenville and former Hodgenville Chief of Police Steven Johnson, alleging violations of state law and seeking relief under 42 U.S.C. § 1983 for violations of her constitutional rights. (Id.) Defendants have moved for summary judgment, arguing that there are no genuine issues of material fact remaining. (D.N. 35) The Court agrees. Because Sanders has not established that Defendants violated her constitutional rights, her § 1983 claim fails as a matter of law. The Court will therefore grant in part Defendants' motion for summary judgment and decline to exercise supplemental jurisdiction over Sanders's remaining state-law claims pursuant to 28 U.S.C. § 1367.

         I. Background

         On March 29, 2014, Sanders's husband Sam Sanders was driving to his residence after watching a basketball game at his father-in-law's house. (D.N. 46, PageID # 487) At the time, Sam Sanders served as the superintendent of the school system of LaRue County, Kentucky, in which Hodgenville is located. Within yards of his residence, Hodgenville Police Officer James Richardson pulled over Sam Sanders on suspicion of driving under the influence. (D.N. 1-2, PageID # 7) The stop occurred on a public roadway. (See D.N. 35-3) A second officer arrived at the scene, and after conducting field-sobriety tests, the officers placed Sam Sanders under arrest. (D.N. 35-6) At some point, the dashboard camera in Richardson's squad car began recording.

         Shortly thereafter, Deeann Sanders arrived at the scene. Sanders wore a white housecoat that rested slightly above knee level, a nightgown underneath, and tennis shoes. (D.N. 46, PageID # 495) The arresting officers later described Sanders as “upset . . . and condescending” during the encounter. (D.N. 35-6, PageID # 162; see also D.N. 35-5) The dashboard camera in Richardson's car captured the entire interaction with Deeann Sanders. (See D.N. 35-7)

         Thereafter, Richardson drove Sam Sanders to the police station for booking procedures. (D.N. 35-6, PageID # 162) Meanwhile, Deeann Sanders went to the home of Terry Cruse, Hodgenville's mayor at the time. (D.N. 35-9, PageID # 175) Cruse, who was asleep, awoke to the sound of “someone beating on [his] back door.” (Id., PageID # 175) When he opened the door, he found Deeann Sanders, who asked him “to personally go down to tell the police officers to let her husband go.” (Id.) Cruse declined. Sanders then arrived at the police station, asked to speak with her husband, and eventually called the LaRue County District Court Judge to inform him of the evening's events. (D.N. 46, PageID # 511, 514) Richardson activated his body camera during the incident. (See D.N. 35-11) The video shows Deeann Sanders repeatedly knocking on the station's door and interrupting the officers during booking. (Id.)

         The next day, Madonna Hornback, who then served as Hodgenville's City Clerk, allegedly received several media requests for the dashcam recording that captured Sam Sanders's arrest. (D.N. 35-14, PageID # 214) She referred the media to Hodgenville Chief of Police Steven Johnson and wrongly informed Johnson that the city must comply with the requests in light of Kentucky's Open-Records Act, Ky. Rev. Stat. § 61.870 et seq. (Id.) Thereafter, Johnson raised the matter with Mayor Cruse, who told Johnson “to comply with the open records laws just as he would with anyone else and to handle it.” (D.N. 35-9, PageID # 176) Johnson then invited the media to view the recording and allowed one cameraman to film the video as it played on a television monitor. Media outlets eventually aired the dashcam video on broadcast television.[1] (See D.N. 1-2, PageID # 8)

         In fact, Johnson may have violated state law by releasing the video. An exception to the Open-Records Act, § 189A.100(2)(e), provides that video recordings of DUI arrests “shall be used for official purposes only.” Any public official or employee who fails to comply with § 189A.100 “shall be guilty of official misconduct in the first degree.” Ky. Rev. Stat. § 189A.100(3).

         In light of § 189A.100, Sam and Deeann Sanders reported Johnson's actions to the Kentucky State Police. (See D.N. 35-16) The Commonwealth eventually charged Johnson with official misconduct in the first and second degree for his release to the media of the dashcam recording. (See D.N. 35-17) A LaRue County jury acquitted Johnson of all charges. (D.N. 35-14, PageID # 225)

         Thereafter, Deeann Sanders brought this action against the City of Hodgenville and Johnson. (D.N. 1-2) Sanders contends that Defendants violated various state laws as well as her constitutional rights by releasing the recording to the media. (See id.) Specifically, she claims that the release of the recording caused her “great humiliation, embarrassment, mental anguish, mental and emotional pain and suffering, and damages to her reputation and character.” (Id., PageID # 8) Defendants have moved for summary judgment.[2] (D.N. 35)

         II. Standard

         Summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). On a motion for summary judgment, the movant “bears the initial responsibility of informing the district court of the basis for its motion[] and identifying those portions of [the record] which it believes demonstrate the absence of a genuine issue of material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The movant may do so by merely showing that the nonmoving party lacks evidence to support an essential element of its case for which it has the burden of proof. See id.

         If the moving party satisfies this burden, the nonmoving party must point to specific facts in the record demonstrating a genuine issue of fact for trial. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986). To survive a motion for summary judgment, the nonmoving party must establish a genuine issue of material fact with respect to each element of each of its claims. Celotex Corp., 477 U.S. at 323 (1986) (noting that “a complete failure of proof concerning an essential element of the nonmoving party's case necessarily renders all other facts immaterial”).

         The mere existence of a scintilla of evidence in support of the nonmoving party's position will be insufficient; instead, the nonmoving party must present evidence upon which the jury could reasonably find for it. Hartsel v. Keys, 87 F.3d 795, 799 (6th Cir. 1996) (citing Anderson, 477 U.S. at 252). This “requires the nonmoving party to go beyond the pleadings and by [its] own affidavits, or by the ‘depositions, answers to interrogatories, and admissions on file, ' designate specific facts showing that there is a genuine issue for trial.” Celotex, 477 U.S. at 324 (quoting Fed.R.Civ.P. 56(e)). For purposes of summary judgment, the Court must view the evidence in the light most favorable to the nonmoving party. Loyd v. Saint Joseph Mercy Oakland, 766 F.3d 580, 588 (6th Cir. 2014) (citing Anderson, 477 U.S. at 255).

         III. Discussion

         The sole basis for federal jurisdiction in this matter is Sanders's § 1983 claim. Specifically, Sanders asserts a failure-to-train claim pursuant to § 1983. (D.N. 1-2, PageID # 10) “Inadequate training can serve as the basis for municipal liability under § 1983 where it ‘amounts to deliberate indifference to the rights of persons with whom the police come into contact.'” Roell v.Hamilton Cty., Ohio/Hamilton Cty. Bd. of Cty. Comm'rs,870 F.3d 471, 487 (6th Cir. 2017) (quoting City of Canton v.Harris, 489 U.S. 378, 388 (1989)). However, as a threshold matter, to properly assert a § 1983 claim “[a] plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a ...

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