Johnnie Givens et al. v. Steven Mantle et al.

Summary

The United States District Court for the Western District of Kentucky dismissed claims against the Louisville Metro Police Department, Louisville/Jefferson County Metro Government, officers in their official capacities, and former Chief Jacquelyn Gwinn-Villaroel. The court held that LMPD is not a suable entity, the complaint failed to plead a viable Monell policy or custom, sovereign immunity barred the state-law claims against Louisville Metro and officers in their official capacities, and the claims against the former chief lacked specific allegations of personal involvement or supervisory misconduct. Claims against the individual officers in their personal capacities remained pending.

Holdings

1. The Louisville Metro Police Department cannot sue or be sued, so the claims against the department were properly dismissed.
2. The amended complaint failed to state a § 1983 claim against Louisville Metro because it did not plausibly allege that an official municipal policy, ratification, custom, or failure to train caused the alleged constitutional violation.
3. The alleged LMPD policy requiring an arrest when an officer has probable cause to believe a person caused physical injury in a domestic-violence situation did not itself establish an unconstitutional municipal policy.
4. Kentucky sovereign immunity barred the state-law tort claims against Louisville Metro and officers sued in their official capacities because plaintiffs identified no statutory waiver.
5. The amended complaint failed to state federal or Kentucky-law claims against Chief Gwinn-Villaroel in her individual capacity because it alleged no personal participation or specific facts showing her own misfeasance, negligent supervision, or failure to train.

Questions Presented

1. Whether the Louisville Metro Police Department is a suable entity.
2. Whether the amended complaint plausibly alleged municipal liability under Monell against Louisville/Jefferson County Metro Government based on an official policy, ratification, an unconstitutional custom, or failure to train.
3. Whether sovereign immunity barred the state-law claims against Louisville/Jefferson County Metro Government and officers sued in their official capacities.
4. Whether the amended complaint plausibly alleged federal or Kentucky-law supervisory liability against Chief Jacquelyn Gwinn-Villaroel in her individual capacity.

Disposition

dismissed