Stanley B. Stallworth v. Dr. Gary Crosby, et al.

Summary

The court addresses a pro se plaintiff’s claims under 42 U.S.C. § 1983 and Alabama law arising from alleged privacy intrusions and interference with expressive and intimate association during related litigation. It denies the defendants’ Rule 12(b)(1) motion, but grants their Rule 12(b)(6) motion on qualified-immunity grounds as to the § 1983 claims. The court also directs the plaintiff to explain whether and how he may proceed against the unserved defendants and postpones consideration of the state-law claims.

Holdings

1. Stallworth sufficiently alleged injury in fact because he alleged impairment of his First Amendment expressive-association rights and interference with his ability to associate with persons of his choosing. The court therefore denied the Rule 12(b)(1) motion to dismiss for lack of standing.
2. The A&M defendants were entitled to qualified immunity because their alleged conduct fell within their discretionary authority and Stallworth did not identify precedent sufficiently particularized to the alleged facts showing that they violated a clearly established constitutional right.
3. Before deciding whether to extend the service period for the unserved defendants, the court required Stallworth to identify the legal authority permitting § 1983 claims against Mr. Canfield, Mr. Blum, and Canfield Computer and to explain why qualified immunity did not apply to the federal claims against Mr. Canfield and Mr. Blum.

Questions Presented

1. Whether Stallworth alleged an injury in fact sufficient to establish Article III standing for his First Amendment expressive-association and intimate-association claims.
2. Whether the served A&M defendants were entitled to qualified immunity from Stallworth's § 1983 claims at the pleading stage.
3. Whether the court should address service and potential qualified-immunity or § 1983 issues concerning the unserved defendants before extending the service period.
4. Whether Stallworth's state-law invasion-of-privacy claims should be resolved at that stage.

Disposition

other