Spring Whiting, an individual and personal representative of the estate of Seth Raven Snyder v. Carbon County, Utah; Sheriff Jeff Wood, in his individual and official capacity; Sergeant Jordan Nelson, in his individual and official capacity; Deputy Deon Gravett, in his individual and official capacity; Deputy Bradly Johnson, in his individual and official capacity; Deputy Edwin Gage Malmgren, in his individual and official capacity; Sergeant Lance Scoville, in his individual and official capacity; Deputy Mark Larsen, in his individual and official capacity; Deputy Victor Turner, in his individual and official capacity; Agent Steven Regruto, in his individual capacity

Summary

The United States District Court for the District of Utah granted the Carbon County Defendants’ partial motion to dismiss claims arising from Seth Raven Snyder’s death while in custody at the Carbon County Jail. The court dismissed the municipal-liability claim against Carbon County under 42 U.S.C. § 1983 without prejudice for insufficiently pleaded policies, customs, causation, and deliberate indifference, and granted leave to amend. Based on the plaintiff’s concessions, the court also dismissed specified supervisory-liability and state-law claims against individual defendants, some with prejudice.

Holdings

1. The Monell claim against Carbon County was insufficiently pleaded because the complaint did not allege sufficient facts establishing an official policy or custom, causation, and the required state of mind.
2. A plaintiff may not survive a motion to dismiss by asserting that discovery may later reveal facts supporting an otherwise insufficient claim.
3. The complaint did not adequately plead deliberate indifference because it alleged no factual pattern of tortious conduct and no facts showing that Carbon County policymakers had notice of, and consciously disregarded, a substantial risk of constitutional violations.
4. Plaintiff was granted leave to amend the Monell claim within 28 days.

Questions Presented

1. Whether the complaint plausibly pleaded a municipal-liability claim against Carbon County under 42 U.S.C. § 1983 based on alleged failures to train, supervise, and discipline jail personnel.
2. Whether allegations concerning Snyder's individual detention and death, together with assertions that additional facts might be obtained in discovery, adequately pleaded an official policy or custom and deliberate indifference.
3. Whether plaintiff should be granted leave to amend the dismissed Monell claim.

Disposition

other