UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

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1 AGNES SOWLE, COUNTY ATTORNEY FOR MULTNOMAH COUNTY Susan M. Dunaway, OSB No Assistant County Attorney 501 S.E. Hawthorne Blvd., Suite 500 Telephone Number: Facsimile Number: (503) Addresses: Of Attorneys for Defendants Multnomah County and Bret Burton UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON JAMES P. CHASSE, JR.; JAMES P. CHASSE; LINDA GERBER; and MARK CHASSE, individually and in his capacity as Personal Representative of the ESTATE OF JAMES P. CHASSE, JR., v. Plaintiffs, Civil No. CV HU DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' COMPLAINT CHRISTOPHER HUMPHREYS; KYLE NICE; CITY OF PORTLAND JOHN DOE FIREFIGHTERS/PARAMEDICS; PORTLAND POLICE BUREAU and OTHER PORTLAND JOHN and JANE DOE OFFICIALS; BRET BURTON; MULTNOMAH COUNTY; MULTNOMAH COUNTY JOHN and JANE DOE DEPUTY SHERIFFS and MEDICAL PERSONNEL; MULTNOMAH COUNTY JOHN and JANE DOE SHERIFF'S OFFICE and OTHER OFFICIALS; TRI-COUNTY METROPOLITAN TRANSPORTATION DISTRICT OF OREGON; and AMERICAN MEDICAL RESPONSE NORTHWEST, INC., Defendants. Page 1 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

2 Defendants Multnomah County and Bret Burton, by and through the undersigned Assistant County Attorney, in response to plaintiffs' Complaint admits, denies and alleges as follows: 1. Defendants admit the allegations contained in paragraph Defendants deny the allegations contained in paragraphs 1, 3-6, 36-38, 41-42, 47-48, 51, 66, 69-72, 75, 79, 81-83, 85-89, 91-97, , , , , , and Defendants are without sufficient knowledge as to the truth of the allegations contained in paragraphs 21-26, 29, 32-35, 39-40, 43, 52-60, 62-65, 67-68, 73-74, 80, 116 and and therefore deny the same. 4. Defendants admit and deny the allegations of paragraphs 78, 84, 90, 98, 104, 110, 115, 124, 128 and 132 as heretofore admitted and denied. 5. In regard to Paragraph 2 of the Complaint, defendants admit that Chasse died on September 17, 2006, and deny each and every other allegation not specifically admitted. 6. In regard to Paragraph 7, defendants admit that plaintiff is alleging that James P. Chasse, Linda Gerber, Mark Chasse and plaintiff's estate have claims against the defendants and that the plaintiffs are seeking damages and injunctive relief and deny each and every other allegation not specifically admitted. Page 2 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

3 7. In regard to the allegations contained in Paragraphs 8-17, defendants admit that plaintiffs' are making the allegations in these paragraphs that plaintiffs' have claims against the defendants based on 42 USC 1983 and 1985 (c), based 42 USC , based on Section 504 of the Rehabilitation Act, ORS 659A.142, Portland City Ordinance and based on ORS and ORS , but defendants deny each and every allegation regarding Deputy Burton, Multnomah County and its employees and officials. Regarding all other defendants against whom allegations are made in paragraphs 8-17, defendants are without sufficient knowledge as to the truth of the allegations and therefore deny the same. 8. In regard to Paragraph 18, defendants admit that plaintiffs' seek damages, costs and attorney fees but denies that plaintiffs are entitled to same. 9. In regard to Paragraph 19, defendants admit that this court has jurisdiction under 28 USC 1331, 1343 and 1367, but deny that 42 USC or are applicable to this case. 10. In regard to paragraph 20, defendants admit that James P. Chasse is deceased but are without sufficient knowledge to admit or deny the rest of the allegations in this paragraph and therefore deny the same. 11. In regard to paragraph 28, defendants admit that Multnomah County is a public body responsible for the conduct of its employees and officials whose conduct is within the course and scope of employment and which does not constitute malfeasance in office or willful or wanton neglect of duty and denies all other allegations in this paragraph. Page 3 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

4 12. In regard to Paragraph 30, admit that supervision of daily operations of the Transit Police Division is provided by the Division's Command Staff and deny all other allegations on the basis of lack of information or belief. 13. In regard to Paragraph 31, admit that defendant Burton, at the time of the incidents underlying the Complaint, was assigned to the Transit Police Division and deny all other allegations on the basis of lack of information and belief. 14. In regard to Paragraph 44, defendants admit that a "spit sock" was used on Chasse at the Multnomah County jail, but deny each and every other allegation not specifically admitted. 15. In regard to Paragraph 45, defendants admit that Humphreys, Burton and others carried Chasse into a cell at the Multnomah County Detention Center and are without sufficient knowledge as to the truth of the rest of the allegations contained in this paragraph and therefore deny the same. 16. In regard to paragraph 45, defendants admit that, while Chasse was at the Multnomah County jail, 911 was not called but defendants are without sufficient knowledge as to the rest of the allegations and therefore deny the same. 17. In regard to paragraph 49, defendants admit that Chasse did not remain at the Multnomah County jail and deny each and every other allegation of this paragraph. Page 4 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

5 18. In regard to paragraph 50, defendants admit that Deputy Burton assisted in carrying Chasse to the police cruiser so that Humphreys, Chasse and Deputy Burton could leave the jail and deny each and every other allegation on the basis of lack of information and belief. 19. In regard to Paragraph 61, to the extent that this paragraph alleges that Multnomah County did not know the importance of or have adequate training, the defendants deny all such allegations and all other allegations not specifically admitted or denied. 20. In regard to Paragraph 76, defendants deny that any conduct on their part was unreasonable, arbitrary or shook the conscious and are without sufficient knowledge as to the truth of the rest of the allegations in this paragraph and therefore deny the same. 21. In regard to Paragraph 77, defendants admit only that plaintiffs' Complaint constitutes tort claim notice to the County and deny each and every other allegation based on lack of information or belief. BY WAY OF FURTHER ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' CLAIMS 1, 2, 3, 4, 5 and 10 BASED ON 42 USC 1983, DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON ALLEGE AS FOLLOWS: 22. FIRST AFFIRMATIVE DEFENSE (Failure to State a Claim Federal) Plaintiffs' claims for relief fail to state a claim upon which relief may be granted. Page 5 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

6 23. SECOND AFFIRMATIVE DEFENSE (Qualified Immunity) These claims are based on actions of the defendants, which actions were unreasonable and taken in good faith and are therefore barred by the Doctrine of Qualified Immunity. 24. THIRD AFFIRMATIVE DEFENSE (Qualified Immunity) These claims are based on propositions of law that were unsettled in the law at the time in question and are therefore barred by the Doctrine of Qualified Immunity. 25. FOURTH AFFIRMATIVE DEFENSE (Respondeat Superior) The County cannot be held liable under 42 USC 1983 for the allegedly tortuous acts of individuals. 26. FIFTH AFFIRMATIVE DEFENSE (ORS ) The individual defendant had the right to detain Mr. Chasse as part of the defendant's community caretaking function. 27. SIXTH AFFIRMATIVE DEFENSE (No Punitive Damages Against Municipalities) Plaintiffs' are barred from seeking punitive damages against municipalities. Page 6 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

7 28. SEVENTH AFFIRMATIVE DEFENSE (Legitimate Law Enforcement Action) The individual defendant cannot be held liable because his actions were reasonable, were undertaken in an emergent situation, do not shock the conscience, and were undertaken only to further legitimate aims of law enforcement. BY WAY OF FURTHER ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' CLAIM 6, DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON ALLEGE AS FOLLOWS: 29. EIGHTH AFFIRMATIVE DEFENSE (Failure to State a Claim) This claim, insofar as it attempts to state a claim based on 42 USC 1985(3), fails to state a claim upon which relief can be granted. 30. NINTH AFFIRMATIVE DEFENSE (Qualified Immunity) The defendants acted in good faith and are therefore entitled to qualified immunity. 31. TENTH AFFIRMATIVE DEFENSE (No Inmutable Class) Plaintiffs' claim is barred because Mr. Chasse did not fall within a class protected by this statute. Page 7 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

8 BY WAY OF FURTHER ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' CLAIM 7, DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON ALLEGE AS FOLLOWS: 32. ELEVENTH AFFIRMATIVE DEFENSE (Failure to State a Claim Federal) Plaintiffs' claim for relief fails to state a claim upon which relief can be granted. 33. TWELVTH AFFIRMATIVE DEFENSE (Failure to State a Claim State) Plaintiffs' claim for relief fails to allege ultimate facts necessary to state a claim. 34. THIRTEENTH AFFIRMATIVE DEFENSE (Legitimate Safety Requirement No Undue Burden) Defendants' actions were based on legitimate safety requirements that are necessary for the safe operation of law enforcement and to act otherwise would create an undue burden on law enforcement operations. 35. FOURTEENTH AFFIRMATIVE DEFENSE (Qualified Immunity) The defendants actions were taken in good faith and therefore the defendants are entitled to qualified immunity. Page 8 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

9 36. FIFTHTEENTH AFFIRMATIVE DEFENSE (Alleged Disability Not Sole Reason for Actions) The allegedly adverse actions taken by the defendants were not taken solely due to Chasse's disability. 37. SIXTEENTH AFFIRMATIVE DEFENSE (No Place of Public Accommodation Under ORS 659A.142 or Portland City Ordinance ) None of the locations where the defendants took actions involving Chasse constitute a place of public accommodation. BY WAY OF FURTHER ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' CLAIMS 8 AND 9, DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON ALLEGE AS FOLLOWS: 38. SEVENTEENTH AFFIRMATIVE DEFENSE (Failure to State a Claim State) Plaintiffs' claims for relief fail to allege ultimate facts necessary to state a claim. Page 9 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

10 39. EIGHTEENTH AFFIRMATIVE DEFENSE (Discretionary Immunity) The plaintiffs' claims for relief are based upon the defendants alleged performance of/or failure to exercise or perform discretionary functions or duties. Defendants are immune from liability from plaintiffs' claims pursuant to ORS (3)(c). 40. NINETEENTH AFFIRMATIVE DEFENSE (Tort Claim Liability Limit) Plaintiffs are barred from seeking damages in excess of those provided by ORS Plaintiffs' state law claims are subject to the conditions, limitations and immunities contained in Oregon's Tort Claim Act, ORS , et. seq TWENTIETH AFFIRMATIVE DEFENSE (No Punitive Damages Available Against Public Body and its Officers) Plaintiffs are barred from seeking punitive damages pursuant to ORS (2). Page 10 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND

11 Page 11 DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND 42. TWENTY-FIRST AFFIRMATIVE DEFENSE (Comparative Negligence) Plaintiffs' injuries were caused in whole or in part by plaintiffs' own negligence. Defendants Multnomah County and Bret Burton reserve the right to add further affirmative defenses as discovery commences. 43. TWENTY-SECOND AFFIRMATIVE DEFENSE (Privilege Justifiable Use of Force) The force used by the individual defendant in restraining Mr. Chasse was privileged and justified under the circumstances. WHEREFORE, defendants pray as follows: 1. That plaintiffs' Complaint be dismissed with prejudice in its entirety; 2. That defendants Multnomah County and Bret Burton recover its reasonable costs, disbursements and attorney fees incurred herein; and 3. That defendants Multnomah County and Bret Burton be granted such other and further relief as may be just and equitable. DATED this 5th day of March, Respectfully submitted, AGNES SOWLE, COUNTY ATTORNEY FOR MULTNOMAH COUNTY, OREGON /s/s Susan M. Dunaway Susan M. Dunaway, OSB No Assistant County Attorney Of Attorneys for Defendants Multnomah County and Bret Burton

12 CERTIFICATE OF SERVICE I hereby certify that on March 5, 2007, I served the foregoing DEFENDANTS MULTNOMAH COUNTY AND BRET BURTON'S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS' COMPLAINT on: Tom Steenson Steenson Schumann Tewksbury Creighton and Rose 815 SW Second Avenue, Suite 500 Portland, OR Jim Rice City Attorney's Office 1221 SW Fourth Avenue, Room 430 Portland, OR by the following method or methods as indicated: ( ) by mailing to said person(s) a true copy thereof, said copy placed in a sealed envelope, postage prepaid and addressed to said person(s) at the last known address for said person(s) as shown above, and deposited in the post office at Portland, Oregon, on the date set forth above. ( ) by causing a true copy thereof to be hand delivered to said person(s) at the last known address for said person(s) as shown above, on the date set forth above. ( ) by mailing via certified mail, return receipt requested, to said person(s) a true copy thereof, said copy placed in a sealed envelope, postage prepaid and addressed to said person(s) at the last known address for said person(s) as shown above, and deposited in the post office at Portland, Oregon, on the date set forth above. ( X ) by facsimile to said person(s) a true copy thereof at the facsimile number shown above, which is the last known facsimile number for said person(s) on the date set forth above. A copy of the confirmation report is attached hereto. Ona Davis Paralegal Page 12 CERTIFICATE OF SERVICE s 501 SE Hawthorne Blvd., Suite 500 Portland, Oregon 97214

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