Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

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1 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DESTINY ANNMARIE RIOS Plaintiff VS. CIVIL ACTION NO. 5:14-cv CITY OF SAN ANTONIO, TEXAS, OFFICER TRAVIS REICH, OFFICER DELGADO, OFFICER VALENZUELA, AND WILLIAM McMANUS, INDIVIDUALLY Defendants ORIGINAL ANSWER OF DEFENDANTS OFFICER TRAVIS REICH, OFFICER DELGADO, OFFICER VALENZUELA AND WILLIAM McMANUS, INDIVIDUALLY TO THE HONORABLE UNITED STATES DISTRICT COURT: NOW COME Defendants, OFFICER TRAVIS REICH, OFFICER DELGADO, OFFICER VALENZUELA AND WILLIAM McMANUS, INDIVIDUALLY, (hereinafter individually by name or collectively as Defendants ), and reserving the right to file other and further pleadings, exceptions and denials, files this their Original Answer to Plaintiff s Original Complaint previously filed herein, and in support thereof would show unto the Court as follows: 1. Defendants deny Plaintiff has alleged a claim against Defendants upon which relief can be granted. 2. Defendants deny they have jointly or severally denied Plaintiff s rights guaranteed by the Constitution and the Laws of the United States of America and the State of Texas as alleged in the opening paragraph of Plaintiff s Original Complaint. Defendants Original Answer to Plaintiff s Original Complaint Page 1 of 11

2 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 2 of 11 JURISDICTION AND VENUE 3. Defendants admit Plaintiff s allegations of Jurisdiction and Venue as alleged in Paragraph 1 of Plaintiff s Original Complaint. Defendants admit this court has supplemental jursidiction to hear state law claims, however, Defendants deny they are liable under any state tort claim theory alleged in Plaintiff s Original Complaint. PARTIES 4. Defendants admit Plaintiff brings this suit as Destiny Annmarie Rios, but are without knowledge or information sufficient to form a belief as to the truth of the allegation she is a resident of San Antonio, Bexar County, Texas, as alleged in Paragraph 1 in Plaintiff s Original Complaint. 5. Defendants admit the allegations contained in Paragraphs 2 through 6, save and except the allegations that Defendants place of employment is 214 E. Nueva Street, San Antonio, Texas, which Defendants deny. FACTS 6. With regard to Paragraph 7 of Plaintiff s Original Complaint, Defendants admit all actions taken by Defendants were undertaken as licensed peace officers and employees of the City of San Antonio and with full authorization of the City of San Antonio. Defendants further admit all actions undertaken by Defendants were undertaken in the course and scope of their employment. Defendants deny the remainder of the allegations contained in Paragraph 7 of Plaintiff s Original Complaint. 7. With regard to Paragraph 8 of Plaintiff s Original Complaint, Defendants are without knowledge or information sufficient to form a belief as to the allegations Plaintiff was walking home where she lived with her grandmother when she was initially approached by Defendants Original Answer to Plaintiff s Original Complaint Page 2 of 11

3 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 3 of 11 Defendant Reich. Defendants admit Defendant Reich did not observe Plaintiff committing a crime when he initially asked to speak with her. Defendants further admit Plaintiff asked why she was being stopped. Defendants deny the remainder of the allegations contained in Paragraph 8 of Plaintiff s Original Complaint. 8. With regard to Paragraph 9 of Plaintiff s Original Complaint, Defendants admit that Defendant Reich stopped Plaintiff and asked her if he could talk to her, and advised her that if she did not wish to talk to him she was free to leave. Defendants admit Plaintiff agreed to talk to Defendant Reich and provided him with her identification, including her social security number, and allowed Defendant Reich to look inside her purse. Defendants admit no illegal drugs or weapons were found inside her purse. Defendants admit Defendant Reich ran a background check on his computer, but deny no criminal records were found. Defendants deny the remainder of the allegations contained in Paragraph 9 of Plaintiff s Original Complaint. 9. In response to Paragraph 10 of Plaintiff s Original Complaint, Defendants admit Defendant Reich advised Plaintiff she was under arrest for an oustanding warrant for prostitution. Defendants deny the remainder of the allegations contained in Paragraph 10 of Plaintiff s Original Complaint. 10. In response to Paragraph 11 of Plaintiff s Original Complaint, Defendants admit that as Plaintiff was resisting arrest, she yelled out she was pregnant, and further admit that a portion of her arrest is captured on video recording. Defendants deny the remainder of the allegations contained in Paragraph 11 of Plaintiff s Original Complaint. 11. In response to Paragraph 12 of Plaintiff s Original Complaint, Defendants admit that Plaintiff was charged with resisting arrest and with prostitution, and both charges were Defendants Original Answer to Plaintiff s Original Complaint Page 3 of 11

4 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 4 of 11 ultimately dismissed. Defendants deny the remainder of the allegations contained in Paragraph 12 of Plaintiff s Original Complaint. 12. In response to Paragraph 13 of Plaintiff s Original Complaint, Defendants admit they were acting within the course and scope of employment and under color of law at the time of the incident. Defendants deny the allegations contained in Paragraph 13 to the extent that they may be read to allege any wrongdoing on the part of Defendants. 13. Defendants deny the allegations contained in Plaintiff s Original Complaint in Paragraphs 14 through 17, inclusive. FIRST CLAIM FOR RELIEF In response to Paragraph 18 of Plaintiff s Original Complaint, Defendants reassert all of their responses to Paragraphs 8 through 17 of Plaintiff s Original Complaint and incorporate same by reference as though fully set forth verbatim. 15. Paragraph 19 of Plaintiff s Original Complaint merely sets forth the language of 42 USC 1983, and no response is required thereto. 16. In response to Paragraph 20 of Plaintiff s Original Complaint, Defendants admit they were acting under color of law at all times relative to the incident made the basis of Plaintiff s suit, and that Defendants are employed by the City of San Antonio. Defendants deny the remainder of the allegations contained in Paragraph 20 of Plaintiff s Original Complaint. 17. Defendants deny the allegations contained in Paragraph 21 a., b., c., d., e. 18. In response to Paragraph 22 of Plaintiff s Original Complaint, Defendants admit Plaintiff was not armed with any kind of weapon at the time of the incident made the basis of this lawsuit. Defendants deny the remainder of the allegations contained in Paragraph 22 of Plaintiff s Original Complaint. Defendants Original Answer to Plaintiff s Original Complaint Page 4 of 11

5 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 5 of Defendants deny the allegations contained in Paragraph 23 of Plaintiff s Original Complaint. 20. In response to Paragraph 24 of Plaintiff s Original Complaint, Defendants admit the Fourth Amendment guarantees security from unreasonable search and seizure. Defendants deny the remainder of the allegations contained in Paragraph 24 of Plaintiff s Original Complaint. 21. Defendants deny the allegations contained in Paragraph 25 of Plaintiff s Original Complaint. 22. Defendants deny the allegations contained in Paragraphs 26, 27 a., b., c., d., e., 28 and 29, inclusive, of Plaintiff s Original Complaint. 23. Defendants deny the allegations contained in Paragraph 30 of Plaintiff s Original Complaint. 24. In response to Paragraph 31 of Plaintiff s Original Complaint, Defendants incorporate all of Defendants responses to the allegations contained in Paragraphs 8 through 17 of Plaintiff s Original Complaint and incorporate those responses by reference as though set forth herein verbatim. 25. Defendants deny the allegations contained in Paragraphs 32 through 34, inclusive, in Plaintiff s Original Complaint. 26. In response to Paragraph 35 of Plaintiff s Original Complaint, Defendants incorporate Defendants responses to the allegations set forth in Paragraphs 8 through 17 of Plaintiff s Original Complaint as though set forth herein verbatim. Defendants deny the remainder of the allegations contained in Paragraph 35 of Plaintiff s Original Complaint. Defendants Original Answer to Plaintiff s Original Complaint Page 5 of 11

6 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 6 of Defendants deny the allegations contained in Paragraph 36 of Plaintiff s Original Complaint. 28. Defendants deny the allegations contained in Paragraphs 37 through 40, inclusive, of Plaintiff s Original Complaint. 29. Defendants deny Plaintiff is entitled to recover any of the relief contained in the prayer of Plaintiff s Original Complaint. 30. Defendants deny each and every, all and singular, the allegations contained in Plaintiff s Original Complaint not specifically admitted hereinabove. JURY DEMAND 31. Defendants demand a jury trial of all Plaintiff s allegations against Defendants. AFFIRMATIVE DEFENSES 32. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Defendants plead their entitlement to the governmental defenses and immunities to which they are entitled pursuant to Chapter , et. seq. of the Texas Civil Practice and Remedies Code, also known as the Texas Tort Claims Act, to include but not limited to, TEX. CIV. PRAC. & REM. CODE (a), (e) and (f), as a matter of law. Defendants also plead all immunity-related defenses available to them under both common and statutory law, including immunity from liability, official immunity, qualified immunity, immunity from damages and limitations on claims and awards. 33. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Defendants assert that on the occasion in question they were acting under color of law, in the course and scope of their employment as licensed, certified peace officers with the City of San Antonio Police Department and within their discretionary authority as peace officers, Defendants Original Answer to Plaintiff s Original Complaint Page 6 of 11

7 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 7 of 11 and that they did not violate Plaintiff s Constitutional rights nor commit any wrongful act. Defendants further say that they were at all times acting in objective good faith in carrying out their duties on the date of the incident in question. Defendants assert that Officers Reich, Delgado and Valenzuela s use of force was reasonably necessary to effect Plaintiff s arrest and does not rise to the degree of force necessary to support a claim for excessive force under 42 U.S.C Defendants assert that any and all force used by Defendants, or any of them, on the date of the incident in question was reasonable, necessary and justified as a result of the Plaintiff s refusal to follow Defendants lawful commands, including, but not limited by specific enumeration to her physically resisting the officers lawful attempts to handcuff her after she had been advised she had an outstanding warrant for prostitution, her actions in repeatedly concealing her hands under her body and leading the officers to believe she may have a weapon or be attempting to hide evidence. A reasonable officer in Defendants position could have reasonably believed the force used by Defendants was necessary under the totality of the circumstance with which Defendants were faced. Defendants therefor assert they are entitled to official immunity and/or qualified immunity to all of Plaintiff s claims as a matter of law. 34. By way of affirmative defense, and without waiving any other defenses, exceptions or denials, Defendants plead the limitation of liability provided by Section (a) of the Texas Civil Practice and Remedies Code in effect at the time of the filing of Plaintiff s Original Complaint and all other applicable damage limitations in effect. 35. By way of affirmative defense, and without waiving any other defenses, exceptions or denials, Defendants assert all force used by Defendants on the date of the incident in question was reasonable, necessary and justified as a result of the Plaintiff s actions or Defendants Original Answer to Plaintiff s Original Complaint Page 7 of 11

8 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 8 of 11 omissions. Defendants further assert that Plaintiff s arrest for an outstanding warrant for her arrest was lawful and was supported by probable cause. 36. By way of affirmative defense, and without waiving any other defenses, exceptions or denials, Defendants would show that the disabilities and/or injuries, if any, which the Plaintiff now has, are the result of the Plaintiff s own actions or omissions on the date of the incident. Plaintiff s actions or inactions, said acts being illegal and intentional, were the sole cause of the incident in question and/or Plaintiff s alleged damages. 37. By way of affirmative defense, and without waiving any other defenses, exceptions or denials, Defendants state that the Plaintiff may have been suffering from preexisting substance abuse, and other physical or mental conditions totally disassociated with the allegations upon which this lawsuit is predicated, which are the sole or partial cause of any mental or physical pain or suffering undergone by Plaintiff. 38. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Defendants plead that the applicable statute of limitations is a bar to one or more of Plaintiff s causes of action against the Defendants. 39. By way of affirmative defense, and without waiving any other defenses, exceptions or denials, Defendants deny that Plaintiff is entitled to recover punitive damages against Defendants or attorney fees in this case under the facts of this case. 40. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Plaintiff s claims for punitive damages against Defendants cannot be sustained to the extent such are not subject to a fact-specific, reasonable limit. Such might consist of a reasonable maximum multiple of compensatory damages or a fixed, reasonable maximum amount, but it must be based only on the specific facts of this case and each Defendant s own Defendants Original Answer to Plaintiff s Original Complaint Page 8 of 11

9 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 9 of 11 acts and omissions, if any, related thereto. Any award of punitive damages which does not bear a reasonable relationship to the specific facts of this case, and which is not limited in specific relation to those facts of each Defendant s own acts and omissions, if any, would violate that Defendant s due process rights guaranteed by the Fourteenth Amendment to the United States Constitution. 41. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Defendants state any award of punitive damages based on anything other than each Defendant s own conduct as alleged in Plaintiff s pleadings upon which Plaintiff goes to trial would violate the due process clause of the Fourteenth Amendment to the United States Constitution and the due process provisions of the Texas Constitution because any other basis for awarding punitive damages in this case would not protect each Defendant against impermissible multiple punishment, and could result in an unjust windfall to Plaintiff. 42. By way of affirmative defense, and without waiving any other defenses, denials or exceptions, Defendants state Plaintiff s claims for punitive damages against Defendants cannot be sustained because under present Federal law, when considering an award of punitive damages, a jury is (1) not provided standards of sufficient clarity for determining the appropriateness and the appropriate size of the punitive damages award; (2) not adequately instructed on the limits of punitive damages imposed by applicable standards of deterrence and punishment; (3) not expressly prohibited from awarding punitive damages or determining the amount of an award of punitive damages, in whole or in part, on the basis of invidiously discriminatory characteristics, including the residence, occupation, wealth and status of each Defendant; (4) permitted to award punitive damages under a standard for determining liability for punitive damages that is vague and arbitrary and does not define with sufficient clarity the Defendants Original Answer to Plaintiff s Original Complaint Page 9 of 11

10 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 10 of 11 conduct or mental state that makes punitive damages permissible; and (5) not subject to sufficient trial court and appellate judicial review for reasonableness and furtherance of legitimate purposes on the basis of objective standards. Any award of punitive damages under the current state of law and Plaintiff s pleadings, thus, would violate each Defendants rights guaranteed by the Fourteenth Amendment to the United States Constitution. 43. Defendants hereby move the Court to order a bifurcated trial of the claim for the actual and punitive damages asserted against Defendants and each of them. WHEREFORE, PREMISES CONSIDERED, Defendants pray that Plaintiff take nothing by this suit and that Defendants be discharged with costs, and for such other and further relief, both general and special, at law or in equity, to which Defendants may be entitled. Respectfully submitted, HOBLIT FERGUSON DARLING, LLP Bank of America Plaza 300 Convent Street, Suite 1450 San Antonio, Texas Tel. (210) Fax (210) BY: N. MARK RALLS State Bar No ATTORNEYS FOR DEFENDANTS, OFFICER TRAVIS REICH, OFFICER DELGADO, OFFICER VALENZUELA AND WILLIAM McMANUS, INDIVIDUALLY Defendants Original Answer to Plaintiff s Original Complaint Page 10 of 11

11 Case 5:14-cv OLG Document 9 Filed 07/31/14 Page 11 of 11 CERTIFICATE OF SERVICE I hereby certify that on the 31 st day of July, 2014, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following: Gayle Caldarola Law Offices of Gayle Caldarola 8301 Broadway, Suite 100 San Antonio, Texas VIA CM/ECF N. MARK RALLS Defendants Original Answer to Plaintiff s Original Complaint Page 11 of 11

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