William Lee Evans v. Deputy Tyler Hoerig, et al.

Summary

The United States District Court for the Eastern District of Wisconsin grants defendants’ motions for partial summary judgment in William Lee Evans’s 42 U.S.C. § 1983 action. The court rejects Evans’s equal protection and Monell racial-profiling claims for lack of evidence of discriminatory purpose and effect, and holds that the deputy’s Taser deployment during the traffic stop was constitutionally reasonable. The court dismisses the case, denies the motion to strike, and denies Evans’s later motions as moot.

Holdings

1. Evans failed to present evidence of both discriminatory purpose and discriminatory effect. Because the record showed a legitimate, nondiscriminatory reason for the traffic stop and no evidence that Black motorists were treated differently from similarly situated motorists, summary judgment was proper for Hoerig and Osieczanek.
2. Fond du Lac County was entitled to summary judgment because a municipality cannot be held liable under Monell when there is no underlying constitutional violation by a municipal employee.
3. Osieczanek's deployment of the taser was constitutionally reasonable, and summary judgment was therefore appropriate on Evans's excessive-force claim.
4. The motion to strike was denied because the court construed Evans's pro se submissions liberally and determined that allowing the response would clarify his responses to multiple summary-judgment motions.

Questions Presented

1. Whether Evans presented sufficient evidence of discriminatory purpose and discriminatory effect to create a genuine dispute on his Fourteenth Amendment equal-protection claims against Deputies Hoerig and Osieczanek.
2. Whether Fond du Lac County could be liable under Monell absent an underlying constitutional violation by a county employee.
3. Whether Osieczanek's deployment of a taser during the traffic stop was objectively unreasonable under the Fourth Amendment.
4. Whether defendants' motion to strike Evans's response brief should be granted.

Disposition

dismissed