ABORTION INDUSTRY IN MELBOURNE, FLORIDA
RANEY V MELBOURNE
DOCKET / CHRONOLOGICAL FILE
DEFENDANT'S MOTION TO DISMISS
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Case No. 99-416-CIV-ORL-19B
MEREDITH T. RANEY, JR.
CITY OF MELBOURNE, FLORIDA,
DEFENDANT'S MOTION TO DISMISS AND MEMORANDUM OF LAW IN SUPPORT OF MOTION (Dispositive}
Defendant the CITY OF MELBOURNE, FLORIDA, by and through undersigned counsel and pursuant to Federal Rule of Civil Procedure 12(b), hereby respectfully requests this Honorable Court dismiss the Complaint for Damages and other relief filed against it herein, for the following grounds and reasons:
1. Failure to state a cause of action under state or federal law.
2. Failure to pay the costs of an action on similar claims previously dismissed by Plaintiff Raney after filing same in the Circuit Court of the Eighteenth Judicial Circuit in and for Brevard County, Florida, in Case No. 97-3763-CA-X.
3. The instant action includes the same general allegations and claims against the same Defendant as the previously-dismissed action. (See Exhibits"A-B"). Thus under Federal Rule 41 (d) and Florida Rule 1.420, this matter should be stayed or dismissed without prejudice until the Plaintiff pays the costs incurred by the Defendant City of Melbourne in the prior state action.
4. Plaintiff lacks standing to bring an action against the City of Melbourne, Florida for the alleged wrongful actions of its Police Department in enforcing a buffer zone around the local abortion clinic, as created by judicial order, under the Freedom of Access to Clinic Entrances' Act.
5. Some or all of Plaintiff' s claims attempted to be alleged under the pertinent Act are barred by the Statute of Limitations.
MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS
I. FACTUAL BACKGROUND:
In March 1997, Plaintiff Meredith Raney sued the City of Melbourne, Florida in the State Circuit Court for the Eighteenth Judicial Circuit in and for Brevard County, Florida, in Case No. 97-3763-CA-X. (Ex. "A"). This Honorable Court can take judicial notice of the allegations in that State Court Complaint. Therein, Plaintiff Raney alleged that in January 1995, April 1995, and January 1996 he was wrongfully arrested without probable cause by police officers of the Defendant City of Melbourne. (Ex. "A"). In its Answer filed to Plaintiff Raney's State Court Complaint, the Defendant City of Melbourne alleged not only that it had probable cause to arrest and detain Plaintiff Raney, but that he had violated a buffer zone established by the Brevard County Circuit Court surrounding the Aware Women's Center for Choice, Inc. Clinic for Reproductive and Abortion Services in Melbourne. (Ex. "C").
The Defendant City of Melbourne's Answer in the State Court case was filed on or about June 12, 1998. The buffer zone had been upheld by courts all the way to the U.S. Supreme Court, and Plaintiff Raney's conviction for violating it upheld. See, Madsen v. WHC, U.S. 753 (1994) (upholding buffer zone) and Alf v. Florida., 116 S. Ct. 65, 133 L. Ed. 2d 27 (1995), denying certiorari to 651 So. 2d 691 (Fla. 5th DCA 1994) (upholding convictions of Raney and 107 others). On July 28, 1998, just six weeks later, Plaintiff Raney's attorney filed a Notice of Voluntary Dismissal of the State Court case.
In the meantime, Plaintiff Raney sued the Aware Women's Center of Melbourne in this Honorable Court, in Case No. 97-1197-CIV-ORL-19. Therein, Plaintiff Raney sued the clinic under the same "Freedom of Access to Clinic Entrances" Act ("F.A.C.E.") under which he now sues the City in this new case, 18 U.S.C. § 248. (Ex. "D"). In that suit, Plaintiff Raney claimed that in arresting him, the police officers of the City of Melbourne were acting as the Clinic's "agents", and "... unlawfully interfered with, threatened, and physically prevented (him) from providing reproductive health services at a facility performing such services." (Ex. "D", p. 1).
An undisputed affidavit filed in that case, confirmed by Plaintiff Raney's sworn deposition testimony in the voluntarily dismissed State Court case, clarified that Plaintiff Raney is a well known anti-abortion activist who participates voluntarily in anti-abortion protests at the Aware Women Clinic in Melbourne. He is not an employee of the Clinic nor provides "reproductive health services" under the ordinary or statutory definitions of that term. As an officer of the Court, undersigned counsel for the City of Melbourne certifies that he witnessed that sworn testimony of Plaintiff Raney while taking his deposition in the State Court case, prior to its voluntary dismissal by Plaintiff Raney.
Nevertheless, Plaintiff Raney has now sued the City of Melbourne, Florida under the alleged basis of the Freedom of Access to Clinic Entrances Act, 18 U.S.C. § 248. He again references the same or similar incidents that resulted in his arrest for violating the Court-Ordered buffer zone around the Clinic in 1995 and 1996, this time labeling them acts of "unlawful intentional attempt to intimidation" by the Defendant City through its police officers. (See, Compl.,¶ 12).
In other words, Plaintiff Raney has freely admitted that he is a staunch anit-abortion activist who has voluntarily on numerous occasions violated the Court-Ordered buffer zone around the Aware Women Clinic, in order to provide his anti-abortion "counseling" to customers and employees of the Clinic. Raney previously sued the City of Melbourne for three incidents in which he was arrested by its officers for violating that buffer zone. Since police officers are not required to analyze the law while on duty but are instead duty-bound to enforce it, it was clear by Plaintiff Raney's own admissions in the State Court case that probable cause existed for his three arrests. That is likely what resulted in Raney's voluntary dismissal of the State Court case.
Raney then pursued his Federal Court case against the Aware Women's Clinic in this District. Again, he has met with deserved defeat. Raney had neither proper standing to sue the Clinic under the Freedom of Access Act nor is it likely the Clinic violated it.
So Mr. Raney is left with a final attempt to bring the City of Melbourne back into the litigiation, with this Federal suit against the City allegedly brought under the Freedom of Access Act. For the grounds stated above and to be further argued below, the Defendant City of Melbourne respectfully submits that Plaintiff Raney's claim fails to state a cause of action under federal or state law, and thus should be DISMISSED.
II. LEGAL ARGUMENT:
Plaintiff Raney now sues the Defendant City of Melbourne solely under the "civil remedies" section of the Freedom of Access to Clinic Entrances Act, 18 U.S.C. § 248. He alleges that he was unlawfully interfered with and physically prevented from "providing reproductive health services" at the Aware Women's Clinic. (Ex. "D"). He alleges that he was "physically removed" from the facility by City police.
This Honorable Court may take judicial notice of the Plaintiff' s prior filings of pleadings and testimony in other lawsuits arising from Plaintiff's anti-abortion activities. Though these are usually matters of fact not appropriate for dismissal motion, ample evidence exists on the record for judicial notice of the undisputed nature of Plaintiff Raney's protest activities and arrests.
In this undisputed context, the City of Melbourne respectfully submits that the Freedom of Access Act was not intended to protect anti-abortion activists such as Plaintiff Raney, who intentionally and voluntarily take criminal action by violating a Court-ordered and approved buffer zone around the abortion clinic, in an effort to draw attention to their cause and become martyrs to it. One District Court has found that a pro-life activist was providing "reproductive health services" as defined under the Act. But that holding is neither dispositive nor compelling upon this Court, and arises from distinctly different facts. See, Greenhut v. Hand, 996 F. Supp. 372 (D.N.J. 1998).
In Greenhut, an anonymous caller made terroristic threats to an anti-abortion activist. The District Court in New Jersey under those circumstances found that the activist as a volunteer for a pro-life association was offering counseling to pregnant women, thus was providing "reproductive health services" protected under the Act. Id. That holding is not relevant to the allegations and facts here.
The Act authorizes criminal penalties and civil remedies against anyone who, "... by force or threat of force, or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to injure, intimidate or interfere with any person because that person is or has been .... obtaining or providing reproductive health services." (18 U.S.C. § 248(a)(1). A private civil action may be brought under that provision, "... only by a person involved in providing or seeking to provide .... services in a facility that provides reproductive health services." (18 U.S.C. § 248(c)(1)(A)).
The Act defines the term "facility" to include the building or structures in which the facility is located. (18 U.S.C. § 248(e)(1)). The term "reproductive health services" includes medical, surgical, counseling and referral services relating to the human reproductive system, including services relating to pregnancy or the termination of a pregnancy. (18 U.S.C. § 248(e)(5).
Clearly, it would frustrate the intent and objectives of the Act to allow anti-abortion activists such as Plaintiff Raney, who intentionally and criminally violates a Court-ordered buffer zone around the Clinic to badger potential clinic patients with his beliefs, to be protected by the civil remedy provisions of this Act. This Act was primarily intended to protect those working in or seeking the services of a reproductive clinic from activist protestors such as Plaintiff Raney, not the protestors themselves. Merely because Plaintiff Raney terms his protest activities as "counseling" does not make him a provider of "reproductive health services" under the Act. Instead, fairness and logic would dictate that he is an opponent of the "reproductive health services" lawfully provided at a place such as this Clinic in Melbourne, not a "provider."
The 36-foot buffer zone created around this clinic that Plaintiff Raney violated on at least three occasions which resulted in his arrest has been judicially approved all the way to the United States Supreme Court. Madsen v. Women's Health Center, Inc., 114 S. Ct. 2516 (1994). Other District Courts have reviewed the enactment of these Court-ordered buffer zones in the context of the Freedom of Access Act. See, i.e., United States vs. McMillan, 946 F. Supp. 1254 (S. D. Miss. 1995). That Court found that a 25-foot buffer zone between the clinic property and abortion protestors which was imposed by judicial inj unction to prevent violations of the Freedom of Access Act was tailored so as not to burden the protestors any more than necessary to provide the requested relief. The protestors could exercise their rights to free speech, while the clinic employees and patients "... could take solace that any threats of force or attempts to damage clinic property would be more difficult to carry out." Id.
Thus here, in the undisputed context arising from the allegations in Plaintiff Raney's Complaint and this Honorable Court's judicial notice of pleadings and testimony in Plaintiff Raney's prior cases against the City of Melbourne and the Aware Women's Clinic arising from the same incidents, it can be concluded that Plaintiff Raney is now attempting to use the shield of a Federal Act intended to protect abortion clinic employees and patients as a sword to sue the City for its lawful enforcement of the injunction Order creating the buffer zone around the Melbourne clinic, by arresting anti-abortion activist Raney when he intentionally and voluntarily violating it.
Plaintiff Raney has implicitly failed in his State Court suit against the City of Melbourne by voluntarily dismissing his suit against the City in the face of undisputed evidence of probable cause for his arrest by the Melbourne police officers. He failed in his suit in this Honorable Court against the Aware Women's Clinic because he did not have standing to sue the clinic under the Act nor did it violate any of the act's provisions. Now, his last and most desperate abuse of the judicial system is the instant action, allegedly brought under the Freedom of Access Act against the City, for his removal from the premises of the Clinic.
Because Plaintiff Raney's litigious effort in this regard is so legally baseless to be frivolous, the Defendant City of Melbourne respectfully requests this Honorable Court not only dismiss the pending Complaint with prejudice but also award the City costs and attorney's fees under Fla. Stat. 57.105, and/or under the pertinent provisions of the Act, 18 U.S.C. § 248(c)(1)(B), et al. Furthermore, even if this Honorable Court disagrees with the Defendant's analysis and arguments, or considers them more appropriate for Summary Judgment, Plaintiff Raney's Complaint is subject to dismissal for its failure to allege the pertinent dates of the Defendant City's alleged "intentional attempted intimidations." (Complaint, ¶ 20).
In fact, apparently realizing that the Statute of Limitations has either run in whole or in part, and that the three arrests incidents in January and April 1995 and January 1996 were already the subject of two prior lawsuits (in State Court against the City filed in 1997, noted above, and in this Honorable Court against the Clinic in 1997, as noted above) (see also the pending Complaint, ¶ 20), Plaintiff Raney specifically attempts to "exclude" those incidents from the claims and allegations made in the pending Complaint. But in otherwise alleging that a violation of the Freedom of Access Act occurred each time that there was "... intentional and attempted intimidation of the Plaintiff by the Defendant," Plaintiff fails to meet the most basic pleading requirement of identifying when the alleged wrongful acts occurred. Without such allegation, and suspecting that the refusal to give such dates was intentional because of the Statute of Limitations, the Defendant City cannot properly respond or fully investigate these otherwise frivolous claims. Simply put, Plaintiff Raney lost his prior State Court and Federal Court litigation over the 36-foot buffer zone in every material respect prior to and since the three occurrences in 1995 and 1996 when he was arrested for intentionally violating the buffer zone. (See case citations above). He cannot continue to relitigate in Court after Court the validity of the buffer zone, or his intentional and criminal violations of it. See, Madsen et al..
The City of Mebourne should be and is entitled to immunity from not being forced repeatedly into pointless and multiple lawsuits and trials on issues that have been conclusively foreclosed by Madsen v. Women's Health Center., 512 U. S. 743 (1944, supra,), and Alf v. Florida, 116 S. Ct. 65 (1995), denying cert. to 651 So. 2d 691 (Fla. 5th DCA), (applying the Madsen buffer zone to convict Plaintiff Raney and 107 others). Both Madsen and Alf approve the application, all the way to the U.S. Supreme Court level, of the judicial injunction against the harassment of the Aware Women's Clinic in Melbourne by Mr. Raney and over 100 others.
Plaintiff Raney and his continual lawsuits must be stopped at this level, or perhaps 100 others also convicted for intentionally violating the buffer zone would follow him to this Court. A ruling favorable to the City of Melbourne here, like the recent ruling in favor of the Aware Women's Clinic on claims by Plaintiff Raney brought under the same Act, would bring a large amount of potential litigation to an end, properly lessening unnecessary burdens on this Court and other's in the future.
In Madsen, the Federal Court explicitly upheld the 36-foot protective buffer zone around the Clinic's reproductive health care facility, enacted by judicial injunction. Enforcement of the buffer zone was held not to burden any asserted First Amendment interests by Plaintiff Raney or other protestors. Mr. Raney's actions in particular were mentioned with alarm both in the Florida Supreme Court Opinion and the concurring opinion of U.S. Supreme Court Justice Stevens.
As Raney admitted in his deposition in his prior case against the Clinic in this Honorable Court, he was the individual who followed a Clinic doctor down U.S. Highway One and made a "gun gesture" toward him. (See, Addendum to the Defendant Clinic's Motion to Dismiss/Motion for Summary Judgment filed in Case No. 97-1197-CIV-ORL-19B). He admitted during his deposition to being the individual in question, but claimed he was "preaching." (See, deposition of Meredith Raney, pre-existing. 59-60, taken 7/13/98, in the above-captioned case).
As conceded in his deposition, Mr. Raney was prosecuted and convicted of contempt for violating the buffer zone. He was found to have intentionally crossed over into the buffer zone, and to be acting in concert with those individuals explicitly named in the Madsen suit. His actions were unlawful, and that was not disputed.
These judicial facts were established in 1995 against Plaintiff Raney, and they should not be relitigated every time he wants to harass the Clinic or the City. Plaintiff Raney litigated and lost the Madsen buffer zone question up through the Florida State Courts. The 5th Ditrict Court of Appeal upheld his two buffer zone convictions. The U.S. Supreme Court denied certiorari on Plaintiff Raney's primary issues in 1995. (Alf, supra).
The Freedom of Access to Clinic Entrances Act does not overrule Madsen, but adds to its protection of the Clinic against protestors such as Plaintiff Raney. The buffer zone keeps him out and away from the Clinic itself and its employees and patients. This Honorable Court having exonerated the Clinic from any civil liability to Plaintiff Raney under the Freedom of Access Act, his now-pending action against the City raised under the same Act should meet a similar fate.
His criminal convictions having been upheld all the way to the U.S. Supreme Court in Alf, applying Madsen, Plaintiff Raney should not be allowed to return years later and transform a valid State Court contempt arrest by the City under Madsen/Alf and other enforcement of the buffer zone into an affirmative federal claim under the Freedom of Access to Clinics Act, 18 U.S.C. § 248. Plaintiff Raney's purpose for his invasion of the 36-foot buffer zone was not only contempt of an injunction upheld by the U.S. Supreme Court, it is also threatening and intimidating activity against the Clinic that would support a verdict under the Act against Plaintiff Raney.
Simply put, Plaintiff Raney does not even contradict his prior sworn testimony by alleging an absence of probable cause in the actions by the City of Melbourne's police officers against him as he continually violated the buffer zone. In fact, probable cause to arrest Mr. Raney was abundantly present here on several occasions, not just the three occurrences in 1995 and 1996. These are matters of law, not disputed fact. When the facts and allegations are not in dispute, whether probable cause existed is a question of law and dismissal or Summary Judgment is appropriate. Marx v. Gumbinner, 905 F. 2d 1503, 1506-1507 (11th Cir. 1990); accord, Herren v. Bowyer, 850 F. 2d 1543, 1547 (11th Cir. 1988); Vermette v. Ludwig, 707 So. 2d 742, 746 (Fla. 4th DCA 1998).
Probable cause to arrest or interfere with the activities of protestor Raney was clearly present on these allegations and the undisputed facts arising from his prior sworn testimony given into the prior case in this Honorable Court and his multiple state court actions. Plaintiff Raney crossed into the forbidden 36-foot buffer zone approved in Madsen by the U. S. Supreme Court. He was a known and frequent harasser of the Clinic. He was plainly and intentionally in contempt of the Court injunction. He never rebutted the police reports, nor even alleged absence of probable cause in his Complaint.
Perhaps most importantly, Plaintiff Raney has been convicted under Madsen as acting in concert or participation with other anti-abortion protestors. His convictions were upheld, and certiorari denied. Alf v. Florida, 116 S. Ct. 65, 133 L. Ed. 2d 27 (1995), denying cert. to 651 So. 2d 691,692, 1211 (Fla. 5th DCA 1994). The holding Alf means that it was illegal as a matter of law for Mr. Raney and his 107 fellow protestors to cross over into the Clinic's buffer zone. Alf meant that Plaintiff Raney could be prosecuted every time he crossed the street and entered into the buffer zone. Most importantly for this case, the holding in Alf means that Plaintiff Raney cannot claim that his contemptuous actions suddenly became a federally protected right, when the Freedom of Access Act was passed by Congress. Id.
Very recently, the 11th Circuit Court applied and analyzed its Marx opinion on probable cause in Rankin v. Evans, 133 F. 3d 1425, 1435-1436 (11th Cir. 1998). The Court stated:
"We conclude that probable cause existed as a matter of law and that the and that existence of such probable cause defeats both the federal and state claims." 133 F. 3d at 1436.
The Rankin Court also stated that Plaintiff had the burden of alleging and demonstrating the absence of probable cause in order to succeed on federal claims. Plaintiff Raney having wholly failed to demonstrate same, and his sworn testimony in this Honorable Court's prior suit brought by him against the Clinic and others demonstrating that the police offers of the City of Melbourne were simply enforcing the Court-ordered buffer zone around the Clinic from the intentionally and criminally contemptuous acts of Plaintiff Raney and others, this Honorable Court should not fail to recognize the undisputed nature of this pending suit. For all the reasons stated herein or to be gleaned from a review of the allegations of Plaintiff Raney's pending Complaint and his allegations and sworn testimony given in the multiple prior actions arising from this same activity, the City of Melbourne respectfully submits that Plaintiff Raney's Complaint filed herein should be dismissed with prejudice and the City's request for fees and costs in defending against it should be granted.
For all the reasons stated herein or to be found from a review of Plaintiff Raney's Complaint in the context of his multiple prior Complaints against the City and the Aware Women's Center Clinic in Melbourne, including his sworn testimony therein, the Defendant City of Melbourne, Florida respectfully submits that the pending Complaint filed against it by Plaintiff Raney should be DISMISSED, with prejudice. An award of costs and attorney's fees under Fla. Stat. 57.105 and the Freedom of Access to Clinic Entrances Act should follow.
I HEREBY CERTIFY that a copy of the foregoing has been furnished to Christopher E. Sapp, Esq., P. O. Box 1012, Lehigh Acres, FL 33970, this 3rd day of May, 1999.
LAMAR D. OXFORD, ESQUIRE <signed>
Fla. Bar No. 0230871
Dean, Ringers, Morgan & Lawton
P.O. Box 2928
Orlando, FL 32802
Attorney for Defendant
"A" Complaint, Raney v. City of Melbourne, filed in the Circuit Court of the Eighteenth Judicial Circuit for Brevard County, Florida, Case No. 97-3763-CA-X
"B" Notice of Dismissal of case in Exhibit "A" above.
"C" Answer of Defendant City of Melbourne in case in Exhibit "A" above.
"D" ORDER, dated 12/3/97, in Raney v. Aware Woman
* * * * Exhibit "C" * * * *
IN THE CIRCUIT COURT IN AND FOR BREVARD COUNTY, FLORIDA CASE NO. 97-3763-CA-X
MEREDITH T. RANEY,
CITY OF MELBOURNE,
ANSWER OF DEFENDANT CITY OF MELBOURNE
The Defendant CITY OF MELBOURNE, by and through and undersigned counsel, hereby respectfully submits its Answer and Affirmative Defenses to Plaintiff's Complaint filed herein:
1. The general allegations set forth in paragraphs nos. 1-4 are admitted.
2. The allegations set forth in paragraphs nos. 5-26 are denied, and Defendant demands strict proof thereof.
1. Plaintiff's Complaint fails to state a valid cause of action against this Defendant under Florida law.
2. Plaintiff's Complaint fails to specify any theory viable under Florida law upon which Plaintiff is proceeding against this Defendant.
3. Plaintiff's Complaint fails to state a valid cause of action under Florida law for false arrest, false imprisonment or malicious prosecution.
4. Plaintiff's Complaint fails to join indispensable parties, including but not limited to the Aware Women's Center for Choice, Inc. and/or its owners Edward W. Windel, Jr. and Patricia B. Windel.
5. At all pertinent times, the personnel of the City of Melbourne had probable cause in which to arrest, detain, prosecute and seek the conviction of Plaintiff for the incidents alleged in the Complaint.
6. The conduct alleged against the Defendant City of Melbourne and its personnel did not rise to the level necessary to constitute a violation of any of Plaintiff's rights, or to serve as a basis for the claims made herein.
7. The conduct of which Plaintiff complains did not cause the Plaintiff injuries, was not grossly disproportionate to the need for action under the circumstances, nor was it inspired by malice or amount to an abuse of official power.
8. The actions taken in order to effect the arrest of Plaintiff were reasonable under the circumstances, undertaken in good faith, and utilized only with such force as necessary to effect the arrest.
9. The arrests of Plaintiff referenced in the Complaint were made with probable cause and reasonable suspicion to believe that he had committed the violations with which he was charged.
10. Plaintiff's damages, if any, were proximately caused or contributed to by the Plaintiff's own actions, thus the claims of Plaintiff should be barred or diminished in accordance with the degree of the Plaintiff's own fault.
11. Plaintiff's injuries, if any, were caused as a result of actions on the part of third parties not within the control or supervision of this Defendant, and this Defendant is therefore not liable for those actions.
12. The claims set forth in Plaintiff's Complaint are barred under the Doctrine of Sovereign Immunity.
13. Plaintiff has failed to comply with the conditions precedent and other requirements set forth under Section 768.28, Florida Statutes.
14. The actions of the Defendant and its personnel did not violate any clearly established laws, and were done in good faith and with probable cause.
15. Any liability of this Defendant to the Plaintiff, which liability is specifically denied, is subject to the terms, provisions, restrictions, limitations, exclusions and other requirements set forth in Florida Statute 768.28, including the statutory cap on damages.
16. By committing acts which established probable cause for the Defendant to believe that the Plaintiff had committed a crime, Plaintiff must be held to have consented to being arrested.
17. The Plaintiff was detained in a reasonable manner and for a reasonable length of time pursuant to applicable Florida law.
18. Defendant affirmatively submits it is entitled to an award of costs and attorney's fees in its favor, incurred by virtue of having to defend itself against the allegations contained in Plaintiff's Complaint.
I HEREBY CERTIFY that a copy of the foregoing has been furnished by Facsimile to Christopher F. Sapp, Esq., P.O. Box 1012, Lehigh Acres, Florida 33970, this 12th day of June 1998.
LAMAR D. OXFORD, ESQUIRE <signed>
Fla. Bar No. 0230871
Dean, Ringers, Morgan & Lawton
P.O. Box 2928
Orlando, Florida 32802 407/422-4310
Attorney for Defendant
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