GOINES v. VALLEY CMTY. SERVS. BD., NO. 15-1589

Decided: May 9, 2016

The Fourth Circuit affirmed in part, vacated in part, and remanded by the court for further proceedings.

Gordon Goines was experiencing difficulties with his cable service. Goines was informed by the cable company that his neighbor was splicing into his cable service and that he should report the theft. Goines proceeded to the police station near his house and reported the theft. Goines suffers from cerebellar ataxia, a neurological condition that causes him difficulties with his speech, balance and certain fine motor functions. The disorder does not affect Goines’ cognitive functioning, and he has no mental health issues. The officers that Goines spoke too regarding his cable service suspected he had mental health problems and asked him if he “wanted to talk to someone” to which Goines responded yes. The officers proceeded to handcuff Goines and involuntarily take him to a mental health institute where he was stripsearched and evaluated by mental health staff. Goines thereafter brought this action under 42 U.S.C. § 1983, alleging that he was unlawfully seized without probable cause in violation of the Fourth and Fourteenth Amendments. The district court dismissed his complaint in its entirety based on Fed. R. Civ. P. 12(b)(6). This appeal followed.

The Fourth Circuit affirmed the district court’s judgment as to the charges against the mental-health evaluator and her employer, but vacated the charges as to the police officers since the complaint was sufficient to survive a motion to dismiss as to those charges. First, the Fourth Circuit determined that the district court erred in treating the allegations of the incident report as true. The Fourth Circuit determined that Goines did not adopt the incident report as true simply by relying on the report for some of the facts alleged in his complaint. Because there was no reliance on the report’s truthfulness, the district court erred in treating as true the factual statements contained in the incident report. The Fourth Circuit then determined that the officers had no probable cause for an emergency mental health detention and Goines’ complaint therefore alleges a constitutional violation. The Fourth Circuit next determined that probable cause did exist for the mental health evaluation because Goines accepted the information set out in the screening report for purposes of his claim. Because probable cause did exist, the complaint failed to allege a constitutional violation against the mental-health evaluator and her employer. The Fourth Circuit therefore affirmed the district court’s dismissal of Goines’ claims against the mental-health evaluator and her employer.

Accordingly, the Fourth Circuit affirmed the judgment of the district court in part, vacated in part and remanded the issue for further proceedings.

Full Opinion

Michael W. Rabb

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