Darrick Edward Wrenn v. State of Oklahoma, et al.

Summary

The United States District Court for the Western District of Oklahoma grants motions to dismiss claims against Deborah Fortune and Kimberly Shanique Shoals in Darrick Wrenn’s action arising from his prosecution for Medicaid fraud. The court concludes that Wrenn failed to plausibly allege that Fortune or Shoals acted under color of state law, failed to plead the racial or class-based animus required for his 42 U.S.C. § 1985(3) claim, and lacked a cause of action under the False Claims Act or Whistleblower Protection Act. The court exercises supplemental jurisdiction over Wrenn’s state-law claims and concludes that his malicious-prosecution and intentional-infliction-of-emotional-distress claims are time-barred.

Holdings

1. Wrenn failed to state a retaliation claim under either statute because he did not allege that he was a government employee, contractor, or agent protected by the statutes' retaliation provisions.
2. Wrenn failed to plausibly allege that either Fortune or Shoals acted under color of state law.
3. Wrenn failed to state a § 1985(3) conspiracy claim because he did not allege racial or otherwise class-based invidiously discriminatory animus.
4. The court had supplemental jurisdiction over Wrenn's state-law claims because they arose from the same criminal prosecution and shared a common nucleus of operative fact with the federal claims.
5. Wrenn's state-law malicious-prosecution claim was barred by Oklahoma's one-year limitations period, and his IIED claim was barred by Oklahoma's two-year limitations period.
6. Dismissal with prejudice was appropriate because amendment would be futile.

Questions Presented

1. Whether Wrenn stated a retaliation claim under the False Claims Act or Whistleblower Protection Act.
2. Whether Fortune and Shoals were plausibly state actors subject to liability under 42 U.S.C. § 1983.
3. Whether Wrenn stated a claim under 42 U.S.C. § 1985(3) by alleging a conspiracy without racial or class-based invidiously discriminatory animus.
4. Whether the court had jurisdiction over Wrenn's state-law claims and whether it should exercise supplemental jurisdiction.
5. Whether Wrenn's state-law malicious-prosecution and intentional-infliction-of-emotional-distress claims were barred by the applicable statutes of limitations.
6. Whether dismissal with prejudice was appropriate because amendment would be futile.

Disposition

other