The opinion of the court was delivered by: Hon. Garrett E. Brown, Jr.
This matter comes before the Court upon the motion (Doc. No. 27) to dismiss filed by Defendant Warren W. Faulk, Camden County Prosecutor. Prosecutor Faulk seeks dismissal of Plaintiffs' Complaint as against him for failure to state a claim upon which relief may be granted. See Fed. R. Civ. P. 12(b)(6). For the following reasons, the Court will grant Defendant's motion.
For the purpose of this motion, the Court accepts as true the factual allegations in the Amended Complaint and draws all reasonable inferences in favor of Plaintiff. See, e.g., Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009). Phillip Carl Martin, Jr. ("Phillip"), is alleged to have been the victim of a "sudden death incident" on January 8, 2008. (Am. Compl. ¶ 6.) Plaintiffs, the Estate of Phillip and members of Phillip's family, filed this action alleging that various Defendants, by virtue of their conduct that caused Phillip's death, deprived Plaintiffs of their Fourth and Fourteenth Amendment rights. (Id. ¶ 4.)
According to the Amended Complaint, Phillip was living with his mother Linda Martin and brother Dwayne Martin at 103 S. 35th Street, Camden, New Jersey, on the date of the incident. (Id. ¶¶ 6-8.) At about 6:30 a.m. on January 8, 2008, Linda Martin responded to someone knocking or ringing the bell to the front door of the family home. (Id. ¶ 28.) After Linda Martin answered the door, four unknown United States Marshals Service Agents, City of Camden Police Officers, and/or other law enforcement officers "burst into" the residence with guns drawn. (Id. ¶ 28.) Plaintiffs contend that three agents climbed the stairs to Phillip's room where he was sleeping, and once the agents were out of sight, Linda and Dwayne Martin heard a gunshot. (Id. ¶¶ 29, 32-34.)
Following these events, Plaintiffs Linda and Dwayne Martin assert that they were unlawfully detained at a Camden police station. (Id. ¶¶ 35-37.) Furthermore, Plaintiffs allege that they were detained for several hours without any information regarding Phillip until Linda Martin was informed that Phillip had committed suicide by shooting himself in the head. (Id. ¶¶ 39-40.) Plaintiffs deny that Phillip committed suicide, contending that Phillip died as a result of a gunshot wound inflicted by one or more of the officers. (Id. ¶¶ 25, 44.)
Plaintiffs also allege that Defendant Warren W. Faulk, the Camden County Prosecutor, irresponsibly failed to supervise the investigation concerning Phillip Martin's death, and that such intentional action or inaction is evidence of deliberate and reckless indifference for the rights of Plaintiffs. (Id. ¶ 98.) In Count V of Plaintiffs' Amended Complaint, Plaintiffs allege that Prosecutor Faulk is liable for failing to properly train employees in crime scene investigation, and such failure is evidence of a deliberate indifference to the constitutional rights of citizens for which it is responsible. (Id. ¶ 121.) Plaintiffs also contend that Prosecutor Faulk knew that five Camden County Police Department officers were reportedly under investigation for violations of the civil rights of suspects at the time of the investigation of Phillip's death. (Id. ¶¶ 96, 98.)
Plaintiffs' Amended Complaint presents federal and state constitutional claims under 42 U.S.C. § 1983 and the New Jersey Civil Rights Act, N.J. Stat. Ann. § 10:6-1 et seq. Prosecutor Faulk now seeks dismissal of the sole claim against him, Plaintiffs' § 1983 claim for failure to train employees in crime scene investigation techniques,*fn1 arguing that Plaintiffs have failed to allege facts that, if proven, would establish a constitutional violation.
A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) may be granted only if, accepting all well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the plaintiff, a court finds that plaintiff has failed to set forth fair notice of what the claim is and the grounds upon which it rests. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). A complaint will survive a motion to dismiss if it "contain[s] sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009) (quoting Twombly, 550 U.S. at 570).
The plausibility standard requires that "the plaintiff plead factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged" and demands "more than a sheer possibility that a defendant has acted unlawfully." Iqbal, 129 S. Ct. at 1949 (citing Twombly, 550 U.S. at 556). Although a court must accept as true all factual allegations in a complaint, that tenet is "inapplicable to legal conclusions," and "[a] pleading that offers 'labels and conclusions' or 'a formulaic recitation of the elements of a cause of action will not do.'" Iqbal, 129 S. Ct. at 1949 (quoting Twombly, 550 U.S. at 555); see also Phillips v. County of Allegheny, 515 F.3d 224, 231 (3d Cir. 2008). In evaluating a motion to dismiss, a court may consider only the complaint, exhibits attached to the complaint, matters of public record, and undisputedly authentic documents if the complainant's claims are based upon those documents. Pension Benefit Guar. Corp. v. White Consol. Indus., 998 F.2d 1192, 1196 (3d Cir. 1993).
Here, Plaintiffs allege that Prosecutor Faulk is liable to Plaintiffs for failing to properly train employees in the area of crime scene investigations, and that such failure is evidence of a deliberate indifference to Plaintiffs' constitutional rights. Prosecutor Faulk challenges the sufficiency of Plaintiffs' Amended Complaint, arguing that Plaintiffs' alleged injury is not causally related to his alleged misconduct. For the following reasons, the ...