Reyna v. City of Santa Cruz

Background

Rhonda E. Reyna filed a self-represented action under 42 U.S.C. § 1983 against 49 defendants. The defendants included government officials and entities, private individuals and organizations, attorneys, psychologists, law-enforcement personnel, and courts. Reyna alleged a conspiracy related to her loss of custody of her daughter and described events from 2014 through 2023, including her arrest by Santa Cruz police officers in June 2021.

An earlier screening order allowed amendment subject to conditions concerning the two-year limitations period for Section 1983 claims, possible judicial, sovereign, and prosecutorial immunity, the need to identify state action by private defendants, Reyna’s ability to assert claims for her daughter, and the federal court’s lack of jurisdiction to review state-court decisions. The case was later reassigned to Judge Alsup. The court warned that failure to follow the earlier order would result in dismissal.

Jurisdiction and pleading standards

The court explained that Section 1983 requires a plaintiff to allege both a constitutional violation and conduct by a person acting under color of state law. It also applied the Rooker-Feldman doctrine, which prevents federal district courts from acting as appellate courts to review state-court judgments. The court said Reyna could not use this action to reverse or appeal decisions by the San Mateo Family Court or other state judicial officers.

First Amendment claim

Reyna alleged violations involving familial association and speech with her daughter. The court dismissed claims against Julia Ferguson, Nancy Read, and Rebecca Bailey because they were private actors and Reyna did not allege facts showing state action. It dismissed claims against family-court mediator Lisa Bergman because Reyna did not identify the relevant time period or specific facts, making timeliness impossible to determine. It dismissed claims against Judge Don R. Franchi based on judicial immunity.

The court also dismissed the First Amendment claims against District Attorney Inspector James Haggarty, Santa Cruz police officers and supervisors, and San Mateo Sheriff’s Deputy Gerano Urena. The allegations did not specify which facts supported the claims, which defendants committed which violations, or why Haggarty was not protected by prosecutorial immunity. The court therefore dismissed Reyna’s First Amendment claims.

Monell claim

A Monell claim is a Section 1983 claim alleging that a local government’s policy, practice, or failure to train caused a constitutional violation. Reyna alleged that San Mateo County, Santa Cruz County, and their sheriff’s offices maintained policies involving misuse of Violence Against Women Act grants, restrictions on mothers’ firearm rights, and inadequate training concerning the alleged strangling of her daughter.

The court found that Reyna did not allege a pattern of grant misuse, did not identify the constitutional right involved in that theory, and relied on a single restraining-order incident rather than a pattern of conduct for the firearm theory. The court also found that an alleged act by a single officer did not establish the pattern of violations generally needed for a failure-to-train claim. In addition, Reyna had not shown that she had custodial rights allowing her to assert claims for her daughter, had not added her daughter as a plaintiff, and had not retained a lawyer for claims brought on the daughter’s behalf. The court dismissed the Monell claim.

Second Amendment claim

Reyna alleged that a state judge’s order, prepared or presented by a Santa Cruz officer, prohibited her from possessing a firearm. The court said it could not exercise jurisdiction over a claim seeking to appeal or overturn that state-court order. The court also found that Reyna’s broader allegations against San Mateo County and Santa Cruz County were vague and unsupported by factual allegations. The court dismissed the Second Amendment claim.

Fourth Amendment claims

Reyna asserted claims concerning an allegedly defective arrest warrant, an unlawful seizure, a strip search, collection of her DNA, confiscation of her prescription glasses, and excessive force during her arrest.

The court applied the Heck rule, which generally prevents a person from seeking damages under Section 1983 when success would necessarily show that an unresolved conviction or confinement was unlawful. The court found that Reyna’s claim that false information led to an unlawful seizure was barred by Heck because it would challenge the basis for her no-contest plea and the legality of her detention. The court dismissed that claim.

The court concluded that the strip-search, DNA-collection, and prescription-glasses allegations were not necessarily barred by Heck, but still failed to state a Fourth Amendment claim. It found that the alleged same-sex strip search during jail booking, the DNA collection as described, and confiscation of glasses upon arrival at the detention facility did not by themselves establish a constitutional violation. The court also found that Reyna provided insufficient detail about how long she was deprived of her glasses. It dismissed those claims.

The court found that the excessive-force claim was not necessarily barred by Heck. However, Reyna alleged that handcuffs caused pain and that she told Officer Sergio Venegas, but did not allege that she asked an officer to loosen or remove them or that such a request was denied. The court found that the allegations did not connect the painful handcuffs to a defendant’s action or failure to act. It dismissed the excessive-force claim and all of Reyna’s Fourth Amendment claims.

Fifth Amendment claim

Reyna alleged that she was held without a grand-jury indictment, subjected to the same offense in two courts, and deprived of life, liberty, or property without due process. The court explained that the Fifth Amendment grand-jury requirement applies to federal courts and has not been applied to the states through the Fourteenth Amendment. It also found that Reyna did not adequately allege that she was tried or punished twice for the same offense. Finally, her due-process allegation was conclusory and did not identify facts, dates, or the defendant responsible for a violation. The court dismissed the Fifth Amendment claim.

Eighth Amendment claim

Reyna alleged that her $100,000 bail was excessive and that she paid $6,000 to be released from jail. The court dismissed the Eighth Amendment claim based on absolute judicial immunity for acts performed by judges in their official capacity. The court said that identifying Inspector Haggarty rather than a judge as the person who set the bail did not change the result for the bail-related claim.

Fourteenth Amendment claims

Reyna alleged discrimination, substantive due-process violations, denial of equal protection, and interference with her right to care for, have custody of, and control her daughter. The court found these allegations conclusory because they did not specify what each defendant did or provide enough information to evaluate timeliness. It also found that the custody-related allegations attempted to reverse or appeal a state-court decision, which the federal district court could not review. The court dismissed the Fourteenth Amendment claims.

Claims under Sections 1985 and 1986

Reyna alleged that all defendants conspired to interfere with her civil rights. The court found that she did not allege specific facts showing an agreement or meeting of the minds among the defendants. It also noted that some alleged conspiracies concerned events before June 23, 2021, which were time-barred unless Reyna could show otherwise. The court dismissed the Section 1985 claim.

Section 1986 provides a claim based on failing to prevent a Section 1985 conspiracy. Because the court dismissed the Section 1985 claim, it also dismissed the Section 1986 claim.

Disposition

The court found that Reyna failed to state a claim under Section 1983. It denied the first amended complaint, dismissed the action without leave to amend, directed the clerk to close the file, and stated that Reyna could appeal by filing a notice of appeal within thirty days after entry of judgment.