Gordon Clark v. State of Connecticut, et al.

Summary

The United States District Court for the District of Connecticut grants Defendants’ motion to dismiss Gordon Clark’s claims arising from the handling and photographing of his deceased wife’s body by Enfield officials and first responders. The court dismisses the federal constitutional, discrimination, municipal-liability, and conspiracy claims, generally without prejudice and with leave to amend, and declines supplemental jurisdiction over the state-law claims. The court sets a deadline of July 19, 2026, for filing an amended complaint.

Holdings

1. A § 1983 plaintiff must plead that each government official, including a supervisor, violated the Constitution through that official's own individual actions; the complaint did not allege personal involvement by the Enfield town manager, mayor, police chief, or director of public safety.
2. The complaint failed to state a plausible substantive due process claim because it alleged only that photographs of Lillian Clark's remains were taken and might have been shared, not that defendants published, publicly shared, or otherwise exploited the photographs for an illegitimate purpose.
3. The gender, age, and race discrimination claims were not plausibly pleaded because the complaint did not allege that Clark was treated differently from similarly situated persons as a result of intentional discrimination or connect the asserted characteristics to any defendant's conduct.
4. The complaint failed to state a § 1983 claim against the Town of Enfield because it alleged neither an underlying constitutional violation nor a municipal policy, practice, or custom causing such a violation.
5. The complaint failed to state a § 1985(3) conspiracy claim because it did not plausibly allege a deprivation of a right or privilege based on racial or other class-based invidious discriminatory animus.
6. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction over the state-law claims under 28 U.S.C. § 1367(c)(3).

Questions Presented

1. Whether the complaint plausibly alleged substantive due process violations based on the taking or possible sharing of photographs of the decedent's remains.
2. Whether the complaint plausibly alleged constitutional discrimination based on gender, age, or race.
3. Whether the complaint alleged personal involvement by supervisory individual defendants sufficient to support individual-capacity claims.
4. Whether the complaint alleged an underlying constitutional violation and a municipal policy, practice, or custom sufficient to support municipal liability under 42 U.S.C. § 1983 and Monell.
5. Whether the complaint plausibly alleged a conspiracy under 42 U.S.C. § 1985(3).
6. Whether the court should exercise supplemental jurisdiction over the state-law claims after dismissing the federal claims.

Disposition

dismissed