Eteghaei v. County of Alameda
- Kandis Westmore
- 4:22-cv-04298
- U.S. District Court · Northern District of California
- 28
In Eteghaei v. County of Alameda, Judge Westmore partly kept alive claims challenging officers’ handcuffing and rifle-pointing during a warrant search.
The order ended all claims brought by Mitra Zade and resolved the remaining claims in favor of the defendants, while allowing ten claims brought by Arash Eteghaei against specified Alameda Defendants to proceed to a possible jury trial. The University Defendants obtained summary judgment on all claims against them.
What happened
In Eteghaei v. County of Alameda, Arash Eteghaei and Mitra Zade sued Alameda County, its officers, University of California defendants, and others over the November 2021 execution of arrest and search warrants at their home. They alleged that officers unreasonably handcuffed them and pointed rifles at them, among other civil-rights and state-law claims.
The court granted the University Defendants’ motion for summary judgment. It granted in part and denied in part the Alameda Defendants’ motion. The court found that a jury could decide whether Defendant Dormer unreasonably handcuffed Eteghaei and whether Defendant Walter unreasonably pointed a rifle at Eteghaei after initially lowering it. It also allowed several related claims against Farruggia, Walter, and Dormer, and a Bane Act conspiracy claim against the Alameda Defendants, to continue. All claims brought by Zade and the remaining claims were resolved in favor of the defendants.
Judge Kandis Westmore ruled that the surviving claims presented factual questions for a jury, while the plaintiffs’ evidence and arguments were insufficient for the other claims. The order therefore granted the University Defendants’ motion and granted in part and denied in part the Alameda Defendants’ motion.
The detailed version
- Eteghaei v. County of Alameda · No. 4:22-cv-04298
- Kandis Westmore
- Oct. 16, 2024
Background
Arash Eteghaei and Mitra Zade sued Alameda County and several Alameda officers, as well as Regents of the University of California and several University Defendants. The case arose from the November 2021 execution of an arrest warrant for the plaintiffs’ adult son, Arian Eteghaei, and a related search warrant for the plaintiffs’ home. The officers detained and handcuffed both plaintiffs while carrying out the warrants. Defendant Walter pointed a rifle toward the plaintiffs, including at Eteghaei’s head after initially lowering it.
The operative complaint asserted claims under 42 U.S.C. § 1983 for unreasonable seizure, unreasonable force, and supervisory liability; claims under the California Constitution and California Civil Code § 52.1, known as the Bane Act; conspiracy; negligent hiring, training, and supervision; assault; battery; intentional and negligent infliction of emotional distress; negligence; false imprisonment and false arrest; and a claim under California Government Code § 7286(b)(5).
Rulings on the Motions
The court granted the University Defendants’ motion for summary judgment. The court held that the University Defendants were not liable for the Alameda officers’ conduct merely because they obtained the search warrant. The court also found that the University Defendants were not shown to have caused a constitutional violation, supervised the Alameda officers, or participated in a Bane Act violation or conspiracy. The University Defendants also received summary judgment on the unreasonable force, intentional infliction of emotional distress, negligent infliction of emotional distress, negligence, assault, and battery claims.
The court granted in part and denied in part the Alameda Defendants’ motion for summary judgment. The court denied summary judgment on these claims:
- Eteghaei’s Fourth Amendment unreasonable-seizure claim against Defendant Dormer based on the handcuffing;
- Eteghaei’s Fourth Amendment unreasonable-force claim against Defendant Walter based on pointing a rifle at him;
- Eteghaei’s supervisory-liability claim against Defendant Farruggia;
- Eteghaei’s California Constitution, article I, section 13 claim against Defendant Dormer;
- Eteghaei’s Bane Act claim against Defendant Walter;
- Eteghaei’s conspiracy-to-commit-a-Bane-Act-violation claim against the Alameda Defendants;
- Eteghaei’s negligent hiring, training, and supervision claim against Defendant Farruggia;
- Eteghaei’s assault claim against Defendant Walter;
- Eteghaei’s battery claim against Defendant Dormer; and
- Eteghaei’s false-imprisonment/false-arrest claim against Defendant Dormer.
Why Those Claims Survived
The court explained that officers may generally detain occupants while executing a search warrant, but handcuffing is a separate and more intrusive use of force that must be justified by the circumstances. Because the operation was assessed as low risk, no weapons were registered to the plaintiffs or their son, and the search sought electronic evidence rather than weapons, a jury could find that Dormer’s handcuffing of Eteghaei was unreasonable. The court also rejected qualified immunity for Dormer because, in its view, existing precedent would have put a reasonable officer on notice that the conduct could violate the Constitution.
The court reached a different conclusion regarding Zade. It found that the officers could reasonably view her as uncooperative and interfering with the search, and it granted summary judgment on the claims based on her handcuffing. The court stated that all claims brought by Zade were among the remaining claims resolved in favor of the defendants.
As to Walter, the court granted summary judgment for the initial pointing of the rifle while officers assessed the situation. It denied summary judgment, however, on the claim that Walter continued pointing the rifle at Eteghaei’s head after lowering it, because a jury could find that Eteghaei was unarmed, generally compliant, and no longer presented a particular danger. The court also denied summary judgment on the related claims against Farruggia and Dormer, including supervisory liability, assault, battery, false imprisonment or false arrest, and the state constitutional claim.
The court granted summary judgment on the Monell claims against Alameda County and the UC Regents because those claims had previously been dismissed. It also granted summary judgment on the intentional-infliction-of-emotional-distress claim against the Alameda Defendants, the negligent-infliction-of-emotional-distress and negligence claims, and the Government Code § 7286(b)(5) claim against Alameda County. The court found the plaintiffs had not provided sufficient evidence or legal argument to create a triable issue on those claims.
Read the full 28-page opinion on CourtListener, the free public archive maintained by the Free Law Project.