Saint Jean v. Altoona, Alabama, City of et al
Filing
57
MEMORANDUM OPINION: The court GRANTS summary judgment for Defendants on all counts except for count II. As to Saint Jean's excessive force claim, the court DENIES summary judgment. Signed by Judge Corey L Maze on 1/6/2025. (LCB)
FILED
2025 Jan-06 PM 03:37
U.S. DISTRICT COURT
N.D. OF ALABAMA
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
MIDDLE DIVISION
JEANTY SAINT JEAN,
Plaintiff,
v.
Case No. 4:22-cv-1107-CLM
ALTOONA, ALABAMA, CITY
OF, et al.,
Defendants.
MEMORANDUM OPINION
Jeanty Saint Jean sues the City of Altoona, Officer Harrelson, and
Unknown Officer A. (Doc. 29). Defendants ask the court to grant summary
judgment on all counts in their favor. (Doc. 45). After reviewing the
evidence in the light most favorable to Saint Jean, the court GRANTS IN
PART AND DENIES IN PART.
BACKGROUND
Saint Jean is a black immigrant. Officer Harrelson pulled Saint
Jean’s car over while he was driving through an Altoona public park.
Officer Harrelson informed Saint Jean that the park was closed to the
public and that Saint Jean’s taillight wasn’t working. When Saint Jean
failed to produce proof of insurance, Officer Harrelson cited Saint Jean
with two tickets. But Saint Jean refused to sign either ticket upon Officer
Harrelson’s request.
In response, Officer Harrelson ordered Saint Jean out of the vehicle
and placed him in handcuffs. But the handcuffs were too small and cut
Saint Jean’s wrists severely enough to require medical attention. Officer
Harrelson then tried to place Saint Jean into his patrol car, and Saint
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Jean resisted. Either because of Officer Harrelson’s use of force (Saint
Jean claims Officer Harrelson kicked him) or Saint Jean’s resistance,
Saint Jean struggled to enter the car. Saint Jean says this struggle
injured his knee, requiring surgery.
Officer Harrelson then searched Saint Jean’s vehicle before
transporting him to jail. At no point during this arrest did Officer
Harrelson recite Saint Jean’s Miranda rights. Saint Jean was charged
with four counts that the Etowah County Circuit County later dismissed
with prejudice because of a procedural deficiency by the State.
Saint Jean now sues Officer Harrison for negligence, unlawful
seizure, and excessive force. Saint Jean also sues unnamed Officer A for
excessive force and the City of Altoona for negligence, malicious
prosecution, and abuse of process.
STANDARD
In reviewing a motion for summary judgment, this court views the
facts and draws all reasonable inferences in the light most favorable to
the non-moving party. See Cuesta v. Sch. Bd. of Miami-Dade Cty., 285
F.3d 962, 966 (11th Cir. 2002). Summary judgment is appropriate when
there is no genuine dispute of material fact, and the moving party is
entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). A genuine
dispute of material fact exists when “the evidence is such that a
reasonable jury could return a verdict for the nonmoving party.” Anderson
v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The party asking for
summary judgment always bears the initial responsibility of informing
the court of the basis for its motion and identifying those portions of the
pleadings or filings which it believes demonstrate the absence of a genuine
issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986).
Once the moving party has met its burden, Rule 56 requires the nonmoving party to go beyond the pleadings and—by pointing to affidavits,
or depositions, answers to interrogatories, and admissions on file—
designate specific facts showing that there is a genuine issue for trial. Id.
at 324.
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ANALYSIS
Saint Jean brings various claims against the three defendants. The
court breaks its discussion into three parts: (1) claims against Officer
Harrelson, (2) claims against the City of Altoona, and (3) claims against
others.
A.
Claims against Officer Harrelson
i.
Count I: § 1983 Unlawful Seizure
Saint Jean sues Officer Harrelson under § 1983 for unlawfully
seizing him after a traffic stop. Traffic stops fall within the Fourth
Amendment meaning of “seizure.” Whren v. United States, 517 U.S. 806
(1996). To lawfully effect a traffic stop, an officer must have reasonable
suspicion. United States v. Campbell, 26 F.4th 860, 880 (11th Cir. 2022).
Reasonable suspicion is “a particularized and objective basis for
suspecting the person stopped of criminal activity,” including traffic
violations. Navarette v. California, 572 U.S. 393, 396 (2014). Reasonable
suspicion can be based on reasonable mistakes of law or fact. Heien v. N.
Carolina, 574 U.S. 54, 61 (2014).
In short, to avoid summary judgment, Saint Jean must show that a
reasonable jury could find Officer Harrelson lacked reasonable suspicion
to survive summary judgment on Count I. He cannot.
Officer Harrelson says that he had reasonable suspicion that Saint
Jean’s broken tail light violated Alabama’s laws governing the color of
rear lights. Combined, three statutes dictate that tail lights must be red,
stop (or brake) lights must be red or yellow, back up lights must be white,
and license plates must be illuminated in white:
(c) Tail lamps.
(1) Every motor vehicle, trailer, semitrailer, and pole trailer
and any other vehicle which is being drawn at the end of a
train of vehicles shall be equipped with at least one tail lamp
mounted on the rear which, when lighted as required, emits
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a red light plainly visible from a distance of 500 feet to the
rear. When vehicles are drawn in a train, only the tail lamp
on the rearmost vehicle need actually be seen from the
distance specified.
(2) Every tail lamp upon every vehicle shall be located at a
height of not more than 60 inches nor less than 20 inches to
be measured as set forth in Section 32-5-242.
(3) Every motor vehicle shall have a tail lamp or a separate
lamp so constructed and placed as to illuminate with a white
light the rear registration plate and render it clearly legible
from a distance of 50 feet to the rear. Any tail lamp or tail
lamps, together with any separate lamp for illuminating the
rear registration plate, shall be so wired as to be lighted
whenever the head lamps or auxiliary driving lamps are
lighted.
Ala. Code. § 32-5-240(c);
(b) Signal lamps and signal devices.
(1) Any motor vehicle may be equipped and when required
under this division shall be equipped with the following
signal lamps or devices:
a. A stop lamp on the rear which shall emit a red or yellow
light and which shall be actuated upon application of the
service (foot) brake and which may but need not be
incorporated with a tail lamp.
b. A lamp or lamps or mechanical signal device capable of
clearly indicating any intention to turn either to the right or
the left and which shall be visible both from the front and
rear.
(2) A stop lamp shall be plainly visible and understandable
from a distance of 100 feet to the rear both during normal
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sunlight and at nighttime and a signal lamp or lamps
indicating intention to turn shall be visible and
understandable during daytime and nighttime from a
distance of 100 feet both to the front and rear. When a
vehicle is equipped with a stop lamp or other signal lamps,
such lamp or lamps shall at all times be maintained in good
working condition. No stop lamp or signal lamp shall project
a glaring or dazzling light.
(3) All mechanical signal devices shall be self-illuminated
when in use at the time mentioned in subsection (a) of
Section 32-5-240.
Ala. Code. § 32-5-241(b); and,
(g) Color of clearance lamps, side marker lamps, and
reflectors.
(1) Front clearance lamps and those marker lamps and
reflectors mounted on the front or on the side near the front
of a vehicle shall display or reflect an amber color.
(2) Rear clearance lamps and those marker lamps and
reflectors mounted on the rear or on the sides near the rear
of a vehicle shall display or reflect a red color.
(3) All lighting devices and reflectors mounted on the rear of
any vehicle shall display or reflect a red color, except the stop
light or other signal device, which may be red, amber, or
yellow, and except that the light illuminating the license
plate or the light emitted by a back-up lamp shall be white.
Ala. Code § 32-5-242(g).
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Body camera footage shows that Saint Jean’s taillight was broken,
resulting in tail lights that appeared to be white and/or projected dazzling
light, either of which violated Alabama law:
Relying on other body cam photos, Saint Jean argues that his
taillight didn’t violate Alabama law because it displayed red and white
light. (Doc. 53, p. 5).
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Saint Jean’s evidence shows that his rear lights did project some red
light. But it also emitted white light in a place other than the license plate,
meaning that Officer Harrelson had reasonable suspicion to believe Saint
Jean was committing a traffic violation. Because we must assume that
jurors will follow Alabama law as instructed, the court finds that no
reasonable juror could find differently.
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In sum, there is no genuine dispute of material fact as to if Saint
Jean’s taillight was broken and emitting a color other than red. Whether
Saint Jean violated Alabama law doesn’t matter. Saint Jean fails to show
that a reasonable jury could find that Officer Harrelson acted without
reasonable suspicion. Because Saint Jean fails to show a constitutional
violation, Officer Harrelson is protected by qualified immunity. Grider v.
City of Auburn, 618 F.3d 1240, 1254 (11th Cir. 2010).
ii.
Count II: § 1983 Excessive Force
Saint Jean also sues Officer Harrelson under § 1983 for excessive
force. Because there is a genuine dispute of material fact as to the type
and amount of force used, the court DENIES summary judgment.
The court analyzes excessive force claims “under the Fourth
Amendment’s ‘objective reasonableness’ standard.” Oliver v. Fiorino, 586
F.3d 898, 905 (11th Cir. 2009). “That standard asks whether the force
applied is objectively reasonable in light of the facts confronting the
officer, a determination [this court makes] from the perspective of a
reasonable officer on the scene and not with the 20/20 vision of hindsight.”
Mobley v. Palm Beach Cty. Sheriff Dep’t., 783 F.3d 1347, 1353 (11th Cir.
2015) (quotations omitted). In determining reasonableness, the court
considers “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
v. Conner, 490 U.S. 386, 396 (1989).
Saint Jean claims he never resisted Officer Harrelson. Instead,
Officer Harrelson’s body cam video shows Saint Jean trying to comply
when cuffed (Body Camera 03:00:28), explaining his arms couldn’t bend
in the way Officer Harrelson was moving them (Body Camera at 03:00:3503:00:04), walking to Officer Harrelson’s car without the need for
manhandling (Body Camera 03:02:54-03:03:09), trying to climb into
Officer Harrelson’s patrol car (Body Camera, 03:03:45-03:03:46), and
reacting when Officer Harrelson “kicked” him. (Doc. 46-1 at 70:1-73:22);
(doc. 46- 1 at 72:12-73:22, 77:5-80:22); (doc. 46-1 at 77:5-23).
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But the video and Officer Harrelson’s testimony tell a different
story. The video shows Saint Jean being argumentative, making Officer
Harrelson repeat his requests, yelling, fighting, and not being compliant.
It’s impossible to tell from the video if Officer Harrelson kicked Saint Jean
or not. And both parties testified to two versions of the incident. (Doc. 462, p. 42); (doc. 46-1, p. 29).
In short, there is a genuine dispute over the kick, and reasonable
jurors could judge what happened differently. Because the court must
view the evidence in a light most favorable to Saint Jean, the court
DENIES summary judgment on Count II.
B.
Claims against the City of Altoona
i.
Count IV: § 1983 Monell Liability
Saint Jean’s first claim against Altoona is for Monell liability under
§1983. Municipalities, like Altoona, can face liability under § 1983 if a
plaintiff shows “a [] policy or custom, whether made by its lawmakers or
by those whose edicts or acts may fairly be said to represent official policy,
inflict[ed] the injury.” Monell v. Dep’t of Soc. Services of City of New York,
436 U.S. 658, 694 (1978). But a court can’t find a municipality vicariously
liable under § 1983.
Saint Jean presents no evidence showing an official Altoona policy
causing his injury. Instead, Saint Jean argues that the “Altoona police
force has a pattern of practice of disproportionately stopping and
harassing Black drivers and immigrants.” (Doc. 29, p. 8). Yet Saint Jean
presents no evidence to support his claim of an unofficial policy of racial
discrimination. (See generally doc. 53 and doc. 29). The only evidence
Saint Jean presents supporting a custom or policy is his own experience
of being pulled over by an Altoona officer on one other occasion over 20
years ago. (Doc. 46-1, p. 95); (doc. 46-3, p. 39). And this isn’t nearly enough
under Monell.
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Because Saint Jean presents no evidence supporting Monell
liability, and because Defendants present evidence refuting Monell
liability, the court GRANTS summary judgment for Defendants.
ii.
Counts V and VI: §1983 Malicious Prosecution and Abuse of Process
Because Saint Jean hasn’t sufficiently satisfied Monell, the court
must GRANT summary judgment for Defendants on Count V (malicious
prosecution under § 1983) and Count VI (abuse of process under § 1983).
iii.
Counts VII and VIII: Alabama law Malicious Prosecution and Abuse
of Process
Saint Jean also accuses Altoona of malicious prosecution and abuse
of process under state law. But the court GRANTS summary judgment
for Defendants on these claims as well because municipalities can’t act
with malice under Alabama law,. Neighbors v. City of Birmingham, 382
So.2d 113 (Ala. 1980); Franklin v. City of Huntsville, 670 So. 2d 848, 850
(ala. 1995); see Ala. Code 1975 § 11-47-190. And malice is required to
establish malicious prosecution and abuse of process. See Mithell v.
Folmar & Associates, LLP, 854 So.2d 1115, 1118 (Ala. 2003); Willis v.
Parker, 814 So.2d 857, 865 (Ala. 2001).
iv.
Count IX: Negligence
Finally, Saint Jean claims that Officer Harrelson acted negligently
in arresting and apprehending Saint Jean and that his negligence can be
attributed to Altoona. (Doc. 29, p. 11). Claims of negligence against either
Officer Harrelson or Altoona fail.
The Alabama Code grants police officers immunity from tort
liability “arising out of his or her conduct in performance of any
discretionary function within the line and scope of his or her law
enforcement duties.” Ala Code. 1975 § 6-5-338(a). And “the plain language
of § 6–5–338(b), Ala. Code 1975, extends that discretionary-function
immunity to the City.” Ex parte City of Gadsden, 781 So.2d 936, 940 (Ala.
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2000). Making a lawful arrest is a discretionary function. Telfare v. City
of Huntsville, 841 So.2d 1222, 1228 (Ala. 2002).
As explained above, Officer Harrelson lawfully arrested Saint Jean.
Perhaps a jury could find Officer Harrelson effected his arrest in an
unlawful manner, but that doesn’t make the arrest itself unlawful.
Accordingly, both Officer Harrelson and Altoona are immune from tort
liability under § 6-5-338.
C.
Claims against Others
i.
Count II: § 1983 Excessive Force against Officer A
The court GRANTS summary judgment for the Defendants on any
claims against fictitious party Officer A. Fictious party practice is
generally not allowed in federal court. Richardson v. Johnson, 598 F.3d
734, 738.
ii.
Count III: Supervisory Liability against Freehling
The court already dismissed Freehling after Saint Jean’s
stipulation. (Doc. 24). The court won’t allow Saint Jean to bring Freeling
back into the case through his amended complaint. As a result, the court
(again) dismisses this count against Freehling.
CONCLUSION
The court GRANTS summary judgment for Defendants on all
counts except for Count II. As to Saint Jean’s excessive force claim, the
court DENIES summary judgment because there is a genuine dispute of
material fact as to if Officer Harrelson used excessive force in carrying out
Saint Jean’s arrest.
DONE and ORDERED on January 6, 2025.
_________________________________
COREY L. MAZE
UNITED STATES DISTRICT JUDGE
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