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Naja v. City of Saratoga Springs

June 19, 2009


The opinion of the court was delivered by: Gary L. Sharpe U.S. District Judge


Following his arrest, plaintiff Travis Naja ("Naja) brought suit against several defendants claiming, among other things, a failure to train and supervise against defendant the City of Saratoga Springs (the "City"), pursuant to 42 U.S.C. § 1983. The City has now filed a motion to dismiss, or in the alternative, for summary judgment. Following review of the City's brief in support thereof, Naja's response, and the record on the matter, the court grants the City's motion.


The following relevant facts are undisputed. On April 2, 2005, at a traffic stop, Naja was arrested for operating a motor vehicle with an expired registration, possessing marijuana, and possessing a firearm. (See Dkt. No. 14-4, Defendant's Ex. A generally; see also Dkt. No. 14-3, Affidavit of Thomas K. Murphy at 5.) All the charges against Naja were later dismissed. (See Dkt. No. 14-3, Affidavit of Thomas K. Murphy at 5.) Naja brought this civil rights action against defendants claiming false arrest, malicious prosecution, unlawful search and seizure, unlawful imprisonment, and excessive force. In addition, Naja brought two claims of municipal liability against the City (Counts VI and VII) for failure to train and failure to supervise. Specifically, Naja contends that on the night in question he should not have been arrested. He contends he should have been given only "a traffic summons" and released, but the City's failure to train the arresting officer and properly supervise him resulted in Naja's false arrest. (See Dkt. No. 15, Affidavit at ¶ 11-13 and Statement of Material Facts at ¶ 2.) The City has responded with a motion seeking dismissal or summary judgment on Naja's claims of municipal liability. For the following reasons, the court grants the City's motion.


Under Rule 12(b)(6), the court "must accept as true all of the factual allegations set out in a plaintiff's complaint, draw inferences from those allegations in the light most favorable to the plaintiff, and construe the complaint liberally." Roth v. Jennings, 489 F.3d 499, 510 (2d Cir. 2007). "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.'" Aschcroft v. Iqbal, 129 S.Ct. 1937, 1949 (2009) (citation omitted). "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 for the misconduct alleged." Id. "The plausibility standard is not akin to a 'probability requirement,' but it asks for more than a sheer possibility that a defendant acted unlawfully." Id.

Under Rule 56(c), a motion for summary judgment is granted if "there is no genuine issue as to any material fact and [] the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(c).

"A municipality may be sued under 42 U.S.C. § 1983 for the constitutional violations of its employees occurring pursuant to an official policy or custom." Ramos v. City of New York, 298 Fed.Appx. 84, 86 (2d Cir. 2008) (citing Monell v. Dep't of Soc. Servs., 436 U.S. 658, 692 (1978)). "Municipal liability may be premised on a failure to train employees when the inadequate training or supervision 'reflects deliberate indifference to... constitutional rights.'" Id. (citing City of Canton v. Harris, 489 U.S. 378, 392 (1989)).

"Specifically, Monell's policy or custom requirement is satisfied where a local government is faced with a pattern of misconduct and does nothing, compelling the conclusion that the local government has acquiesced in or tacitly authorized its subordinates' unlawful actions." Reynolds v. Giuliani, 506 F.3d 183, 192 (2d Cir. 2007) (citations omitted). "In City of Canton, the Supreme Court held a city's failure to train its subordinates satisfies the policy or custom requirement only where the need to act is so obvious, and the inadequacy of current practices so likely to result in a deprivation of federal rights, that the municipality or official can be found deliberately indifferent to the need." Id. (citing City of Canton v. Harris, 489 U.S. 378, 390 (1989)).

"'Deliberate indifference' involves the conscious disregard of the risk that poorly-trained employees will cause deprivations of clearly established constitutional rights." Wray v. City of New York, 490 F.3d 189, 196 (2d Cir. 2007) (citation omitted). "'[A] training program must be quite deficient in order for the deliberate indifference standard to be met: the fact that training is imperfect or not in the precise form a plaintiff would prefer is insufficient to make such a showing.'" Reynolds, 506 F.3d at 193 (quoting Young v. City of Providence ex rel. Napolitano, 404 F.3d 4, 27 (1st Cir. 2005)). "A training program is not inadequate merely because a few of its graduates deviate from what they were taught." Jenkins v. City of New York, 478 F.3d 76, 95 (2d Cir. 2007). "[W]here [] a city has a training program, a plaintiff must-- in addition-- identify a specific deficiency in the city's training program and establish that [the] deficiency is closely related to the ultimate injury, such that it actually caused the constitutional deprivation." Wray, 490 F.3d at 196 (internal quotations and citations omitted).

As to a plaintiff's claims of failure to supervise, the plaintiff must "(1) establish state defendants' duty to act by proving they should have known their inadequate supervision was so likely to result in the alleged deprivations so as to constitute deliberate indifference...; (2) identify obvious and severe deficiencies in the state defendants' supervision that reflect a purposeful rather than negligent course of action; and (3) show a causal relationship between the failure to supervise and the alleged deprivations to plaintiffs." Reynolds, 506 F.3d at 193.

With these precepts in mind, the court determines that Naja has failed to establish the necessary elements to prove municipal liability. In his two-page brief, Naja asserts the City's "failure to train and supervise was so inadequate and negligent, that it was a direct cause of deprivation of Plaintiff's Constitutional rights." However, Naja does not indicate with specificity the alleged inadequacies in the City's training program and its supervision to establish a claim for failure to train and supervise. Naja attempts to provide specific examples when he states:

General Order 50.20 of the Saratoga Springs Police Department, 'Field Interviews & Pat Down Searches,' [] only explains briefly when an Officer can conduct a 'Pat-Down' search. If the Order was more specific and detailed, it would have provided information ...

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