Taylor v. San Francisco Sheriff's Department

Background

Mechiel Taylor represented herself in a second amended complaint against seven defendants. She alleged civil-rights and state-law claims arising from events during her employment as a baking teacher at Santa Rita Jail. Taylor alleged that Nicole Tremaine Allen, a deputy sheriff, harassed and monitored her at work and later contacted her repeatedly, remotely changed her home thermostat, entered her home, blocked her exit, and used her phone. Taylor also alleged that Five Keys, the City and County of San Francisco, Alameda County, and other individuals failed to respond adequately to her complaints and related requests for assistance.

Taylor asserted claims under the First, Fourth, and Fourteenth Amendments through 42 U.S.C. § 1983, hostile-work-environment claims under Title VII and Title IX, and California claims for trespass to personal property and intrusion upon seclusion. The defendants filed three motions to dismiss under the rule allowing dismissal for failure to state a legally sufficient claim.

Five Keys Defendants

The court construed Taylor’s allegations as asserting claims against Five Keys even though portions of the second amended complaint identified the employer inconsistently. The court dismissed with prejudice Taylor’s § 1983 and state-law claims against Five Keys, Steve Good, and Melanie Fukuhara. It held that Five Keys, a California charter school, was protected by Eleventh Amendment immunity for those claims, and that Good and Fukuhara were either protected by that immunity when sued in their official capacities or were not adequately linked to a personal-capacity violation. The court did not dismiss Taylor’s Title VII and Title IX claims against Five Keys, so those claims will go forward.

City and County of San Francisco

Taylor alleged that the City and County of San Francisco was her employer, pointing to employment documents, human-resources communications, tax forms, and the relationship between the San Francisco Sheriff’s Department and Five Keys. The court found those allegations sufficient at the pleading stage to plausibly allege an employment relationship. It therefore rejected the argument that the city and county could not be liable because it was not involved in the alleged conduct and denied its motion to dismiss. Taylor’s Title VII and Title IX claims against the city and county will go forward.

Alameda Defendants

The court dismissed with prejudice Taylor’s First Amendment and Fourth Amendment § 1983 claims against Allen, finding that the allegations did not plausibly show a constitutional violation or that Allen acted under state authority during the relevant personal conduct. The court allowed Taylor’s Fourteenth Amendment equal-protection claim against Allen to go forward. It found that allegations that Allen used state-granted access to jail security systems to monitor and control Taylor sufficiently connected the alleged harassment to Allen’s role as a deputy sheriff at the pleading stage.

The court dismissed with prejudice Taylor’s § 1983 claims against Alameda County because she did not adequately allege a county policy, custom, failure to train, or ratification that caused a constitutional violation. The court also dismissed with prejudice Taylor’s Fourteenth Amendment claim against Gregory Ahern because the complaint did not plausibly allege that he participated in, directed, knew about, or approved the alleged constitutional violations. Judgment was entered for Ahern.

The court dismissed Taylor’s Title VII claim against Alameda County without leave to amend because the allegations did not plausibly show that the county was her employer during the relevant period. The court denied dismissal of Taylor’s Title IX claim against Alameda County, finding that the alleged delays, hostile interview, lack of remedial action, and other circumstances plausibly supported deliberate indifference to known harassment.

The court allowed Taylor’s trespass-to-personal-property claim against Allen to go forward based on allegations that Allen took control of Taylor’s thermostat and phone. It dismissed with prejudice the trespass claim against Alameda County because the alleged conduct was not connected to Allen’s employment in a way that could make the county responsible. The court also allowed Taylor’s intrusion-upon-seclusion claim against Allen to go forward based on the alleged intrusions into Taylor’s home, thermostat, phone, and private affairs.

Disposition

The Five Keys Defendants’ motion to dismiss was granted in part and denied in part. The City and County of San Francisco’s motion was denied. The Alameda Defendants’ motion was granted in part and denied in part. Daniel Brodie was dismissed because Taylor dropped her claims against him. Lisa Haynes and Mary Vigil were dismissed because Taylor made no allegations against them. Judgment was entered in favor of Daniel Brodie, Lisa Haynes, Mary Vigil, Steve Good, Melanie Fukuhara, and Gregory Ahern. The remaining defendants were ordered to file answers by November 19, 2024. Judge Ryu set an initial case-management conference for December 4, 2024.