United States District Court, N.D. Mississippi, Oxford Division
COREY BRYANT, a Minor, by and through Charles and Shari Bryant, Natural Parents; and CHARLES and SHARI BRYANT, Plaintiffs,
CITY OF RIPLEY, MISSISSIPPI; SOUTH TIPPAH SCHOOL DISTRICT; RIPLEY POLICE DEPARTMENT; SCOTT WHITE, in his Official and Individual Capacities; RODNEY WOOD, in his Official and Individual Capacitites; and ALLEN STANFORD, in his Official and Individual Capacities, Defendants.
NEAL B. BIGGERS, Jr., District Judge.
Came on to be heard this day the motion for summary judgment of Defendants City of Ripley, Mississippi,  Scott White, and Rodney Wood. Upon due consideration of the motion, response, exhibits, and supporting and opposing authority, the court is ready to rule.
Factual and Procedural Background
Plaintiff Corey Bryant was a student attending Ripley High School when, on October 17, 2011, he was arrested at school by defendant Ripley police officer Rodney Wood and questioned in the school office in the presence of defendant vice principal Allen Stanford regarding his alleged involvement in the vandalism of a security camera belonging to the Ripley Parks and Recreation Department. The vandalism occurred after school hours on October 14, 2011. The camera captured the image of the teenaged suspect, another Ripley High School student, prior to the vandalization.
Upon arriving at the school, Wood informed Stanford that he had identified the suspect in the captured image and, with Stanford's approval, removed the suspect student from his classroom and brought him to the school's office. The suspect student informed Stanford that the vandalism did not occur during school hours or during a school event. The student then implicated Bryant in the matter.
Stanford told Wood to remove Bryant from his classroom and bring him back to the school's office. Wood did so, placing Bryant under arrest and informing him that he was being charged with malicious mischief. Neither Stanford nor Wood notified Bryant's parents at this point. Bryant alleges that Stanford interrogated him, repeatedly asking if Bryant was involved in vandalizing the camera, while Wood, in full uniform, blocked the doorway. Stanford denies asking Bryant any question other than whether the incident occurred during school hours or during a school activity. The other suspect student testified that school officials, including Stanford, questioned him directly as to whether he was involved in the vandalism.
Stanford stated in an affidavit that Bryant and the other suspect student informed him that the incident occurred after school hours. He further stated, "Consistent with the treatment of the other student, school officials did not question Bryant further since this was not a school matter. Bryant did state to Officer Wood that it was the other student instead of him who vandalized the security camera." After the interrogation, Wood handcuffed Bryant to the other student suspect and escorted them out of the school and to his patrol car.
The plaintiffs filed this Section 1983 action on April 2, 2012, against the City of Ripley, South Tippah School District, Ripley Police Department, and Chief of Police Scott White, as well as Wood and Stanford in their official and individual capacities. The plaintiffs assert a constitutional violation of Bryant's right to be free from unreasonable search and seizure under the Fourth Amendment, a Fourteenth Amendment due process claim and familial relations claim, and a number of state law tort claims. Defendants City of Ripley, White, and Wood have now filed a motion for summary judgment.
Standard of Review
Summary judgment is appropriate when the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits, if any, show that there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law. Fed.R.Civ.P. 56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). An issue of material fact is genuine if a reasonable jury could return a verdict for the nonmovant. Anderson v. Liberty Lobby, 477 U.S. 242, 248 (1986). On a motion for summary judgment, the movant has the initial burden of showing the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). If the movant makes such a showing, the burden then shifts to the nonmovant to "go beyond the pleadings and by... 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 Corp., 477 U.S. at 324 (quoting Fed.R.Civ.P. 56(c), (e)). In reviewing the evidence, this court must draw all reasonable inferences in favor of the nonmoving party and avoid credibility determinations and weighing of the evidence. Reeves v. Sanderson Plumbing Prods. Inc., 530 U.S. 133, 150 (2000). In doing so, the court must disregard all evidence favorable to the moving party that the jury is not required to believe. Reeves, 530 U.S. at 151. Plaintiff's "burden is not satisfied with some metaphysical doubt as to the material facts, ' by conclusory allegations, ' or by only a scintilla' of evidence." Little v. Liquid Air Corp., 37 F.3d 1069, 1975 (5th Cir. 1994) (citations omitted).
The defendants assert that Heck v. Humphrey controls this case. The court agrees. Under Heck v. Humphrey, 512 U.S. 477 (1994), a plaintiff seeking to recover damages under Section 1983 for "harm caused by actions whose unlawfulness would render a conviction or sentence invalid... must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court's issuance of a write of habeas corpus." Id. at 486-87. "A claim for damages bearing that relationship to a conviction or sentence that has not been so invalidated is not cognizable under § 1983." Id. at 487. The crucial question in determining whether Heck precludes the plaintiff's § 1983 claims is "whether a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence; if it would, the complaint must be dismissed unless the plaintiff can demonstrate that the conviction or sentence has already been invalidated." Id.
The present case concerns a Ripley police officer who detained and arrested the plaintiff, Corey Bryant, who was a minor at the time, pursuant to Mississippi's Youth Court Act, for committing the act of malicious mischief in violation of Miss. Code § 97-17-67, a misdemeanor offense. The parties dispute whether the officer had probable cause to arrest and the manner in which the officer conducted the arrest. The Youth Court, however, found that Bryant committed the act charged and sentenced him to pay a $40 fine as restitution. This adjudication has not been reversed on appeal, expunged, or otherwise set aside.
The plaintiffs assert that Heck is inapplicable here and argues that in Mississippi a youth court adjudication does not rise to the level of a conviction. Section ...