Langham v. Granzella

Background

Malik Langham initially sued California Highway Patrol Officers Antonio Granzella, Joseph Dagnino, Sean Butler, and Kenton Dewald. He alleged that officers stopped him while he was driving on a freeway, ticketed and handcuffed him, towed his car, searched the car, and later left him at a gas station. Langham alleged that he showed the officers a valid Florida driver’s license, but they told him he could not use it in California and treated him as unlicensed.

His amended complaint asserted Fourth Amendment claims under 42 U.S.C. § 1983 and California Civil Code § 52.1, as well as claims for assault, battery, invasion of privacy, and negligence. In an earlier order, the Court took judicial notice of records showing that Langham had been convicted in traffic court of driving while unlicensed and speeding. The Court dismissed the § 1983 claim as barred by the Supreme Court’s decision in Heck v. Humphrey and dismissed the state-law claims because Langham had not alleged compliance with the Government Claims Act. The Court allowed amendment.

Current motion

Langham’s second amended complaint dropped the § 1983 claim and alleged only a violation of California Civil Code § 52.1. The defendants moved to dismiss, arguing that the Court no longer had subject-matter jurisdiction. Langham did not file a response. After the Court issued an order requiring him to explain why the motion should not be granted, he stated that he was litigating without a lawyer, was proceeding in good faith, and believed the case could not proceed based on the defendants’ motion.

Court’s reasoning

The Court applied 28 U.S.C. § 1367(c)(3), which allows a federal court to decline supplemental jurisdiction—the authority to hear related state-law claims—when it has dismissed all claims over which it had original federal jurisdiction. The Court found that the second amended complaint contained no federal claim. Because the case was still at an early stage, the Court concluded that judicial economy, convenience, fairness, and respect for state courts favored declining supplemental jurisdiction over the remaining state-law claim.

Disposition

The Court GRANTED the defendants’ motion to dismiss. It dismissed the California Civil Code § 52.1 claim WITHOUT PREJUDICE to refiling in state court if Langham could do so consistently with state-court requirements and the Government Claims Act. The Clerk was directed to close the case.