William Louis Armstrong, III v. City of Milwaukee, Chad Crivello, Milwaukee County, and Salah Al-Zalloum

Summary

The United States District Court for the Eastern District of Wisconsin grants Milwaukee County’s motion for judgment on the pleadings in William Louis Armstrong, III’s pro se civil rights action. The court holds that Armstrong failed to plausibly plead a Monell policy, custom, or failure-to-train claim attributable to the County, and dismisses the County with prejudice. The court also grants the County’s motion to file a corrected reply brief and denies Armstrong’s motions for default judgment and to stay the proceedings.

Holdings

1. Armstrong failed to state a Monell claim against Milwaukee County because he did not plausibly allege that a County policy, custom, practice, or final policymaker caused the alleged constitutional violations. The alleged conduct involved City employees, and the identified police orders and municipal ordinances were not County policies.
2. Armstrong failed to state a failure-to-train claim against Milwaukee County because he identified no County employee, policymaker, or training policy and alleged no pattern of similar constitutional violations or other facts showing deliberate indifference.
3. Armstrong lacked standing to pursue that theory because he did not allege that he had been imprisoned for failure to pay a fine, and an alleged future threat of imprisonment was hypothetical.
4. The court declined to strike the County's answers or deem the challenged allegations admitted. Any imprecision in the answers had been resolved by the parties' briefing and granting such relief would not expedite the proceedings.
5. Armstrong was not entitled to default judgment because he had not obtained entry of default and Milwaukee County was not in default.
6. Armstrong was not entitled to a stay or extension of time because he failed to show that the related case pending before the Supreme Court was pertinent or that he was likely to prevail, and his argument was perfunctory.

Questions Presented

1. Whether Armstrong adequately pleaded a Monell municipal-liability claim against Milwaukee County based on a County policy, custom, or practice.
2. Whether Armstrong adequately pleaded a Monell failure-to-train claim against Milwaukee County.
3. Whether Armstrong had standing to challenge an alleged policy concerning imprisonment for nonpayment of fines in County facilities.
4. Whether the County's allegedly imprecise or qualified answers required striking the answers or deeming allegations admitted.
5. Whether Armstrong was entitled to default judgment against Milwaukee County.
6. Whether Armstrong was entitled to a stay or extension of time based on a related petition pending before the Supreme Court.

Disposition

other