The U.S. Court of Appeals for the Ninth Circuit dismissed a federal civil rights lawsuit against multiple Arizona defendants in an unpublished memorandum decision filed Jan. 28, 2026. The case, *Bey v. State of Arizona* (No. 24-3393), involved claims brought under 42 U.S.C. § 1983 alleging violations of federal and state law arising from a traffic stop and subsequent arrest and detention.
Plaintiff Darius Johnson Bey, representing himself pro se, appealed from a district court judgment that dismissed his Section 1983 action. The defendants included the State of Arizona in care of Attorney General Kris Mayes, the Arizona Department of Administration Risk Management Division, the Phoenix Police Department, individual officers Curtis Klusek and Andrea Lamphier, and the Arizona Peace Officer Standards and Training Board.
The Ninth Circuit panel, consisting of Circuit Judges Kim McLane Wardlaw, Richard Clifton, and Ryan Nelson, unanimously concluded the case was suitable for decision without oral argument under Federal Rule of Appellate Procedure 34(a)(2). The court submitted the case for decision on Jan. 22, 2026, just six days before issuing its ruling.
According to court records, the underlying claims stemmed from a traffic stop that led to Bey's arrest and detention. The plaintiff alleged violations of both federal civil rights laws and state law claims in connection with the incident. The case originated in the U.S. District Court for the District of Arizona, where District Judge Michael T. Liburdi presided over the proceedings.
The Ninth Circuit applied de novo review to the district court's summary judgment, citing *Desire, LLC v. Manna Textiles, Inc.*, 986 F.3d 1253, 1259 (9th Cir. 2021). The appeals court also reviewed the dismissal under Federal Rule of Civil Procedure 12(b)(6) using the same standard, referencing *Benavidez v. County of San Diego* for the applicable legal framework.
Section 1983 cases allow individuals to sue state and local officials for violations of constitutional rights committed under color of state law. These lawsuits frequently arise from encounters with law enforcement, including traffic stops, arrests, and detention conditions. To succeed in a Section 1983 claim, plaintiffs must demonstrate that a person acting under color of state law deprived them of rights secured by the Constitution or federal law.
The case highlights challenges faced by pro se litigants in federal civil rights litigation. Self-represented plaintiffs must navigate complex procedural requirements and legal standards without the benefit of legal counsel. Federal courts are required to liberally construe pro se pleadings, but plaintiffs must still meet basic pleading and legal sufficiency requirements.
The involvement of multiple defendants reflects the typical structure of civil rights cases arising from law enforcement encounters. The State of Arizona, represented through the Attorney General's office, the state's risk management division, the municipal police department, individual officers, and the state's police training board all faced claims in the litigation.
The Arizona Peace Officer Standards and Training Board, known as AZPOST, establishes training standards and certification requirements for law enforcement officers throughout the state. Its inclusion as a defendant suggests the plaintiff may have alleged systemic training or oversight failures in addition to specific constitutional violations by individual officers.
The case was designated as not appropriate for publication, meaning it cannot be cited as precedent except as provided by Ninth Circuit Rule 36-3. Unpublished decisions are routine in federal appellate courts for cases that do not establish new legal principles or involve novel questions of law.
The district court case number 2:23-cv-00477-MTL-CDB indicates the lawsuit was filed in 2023 in the U.S. District Court for the District of Arizona. The relatively quick progression from district court to appellate decision suggests the case involved dispositive motions that resolved all claims without trial.
While the specific factual allegations and legal theories are not detailed in the available court documents, the case represents another example of civil rights litigation arising from police encounters being resolved in favor of government defendants. The dismissal at both the district court and appellate levels indicates the plaintiff was unable to state viable claims or present sufficient evidence to survive summary judgment.
The decision adds to the body of Ninth Circuit case law addressing Section 1983 claims against state and local officials, though its unpublished status limits its precedential value. The case demonstrates the challenges plaintiffs face in successfully pursuing civil rights claims through federal court, particularly when proceeding without legal representation.