Faison v. Alameda County

Background

The plaintiffs brought claims under 42 U.S.C. § 1983 against individual officers, Alameda County, and The East Bay Regional Park District (the “District”). They alleged that District Officer Knea tased Plaintiff Deontae Charles Faison while he was in the estuary at Martin Luther King Jr. Regional Shoreline Park, causing life-threatening injuries.

The plaintiffs originally asserted claims against both Alameda County and the District under Monell v. Department of Social Services. A Monell claim seeks to hold a government entity liable under Section 1983 for a constitutional violation caused by the entity’s policy, practice, or custom. The plaintiffs later amended their complaint to assert Monell liability only against the District.

The District and Officer Knea moved to dismiss the Monell claims against the District. The court decided the motion based on the parties’ written submissions and concluded that oral argument was unnecessary.

Court’s Analysis

At the motion-to-dismiss stage, the court was required to accept plausible factual allegations as true, but it explained that conclusory statements and formulaic recitations of a claim’s elements are insufficient.

The plaintiffs alleged that the individual defendants acted under an expressly adopted official policy or a widespread or longstanding practice or custom of the District. However, the complaint did not identify any such policy, practice, or custom. Because a government entity may be liable under Section 1983 only when its policy, practice, or custom was the moving force behind the constitutional violation, the court concluded that the complaint did not adequately state a Monell claim.

Disposition

The court granted the defendants’ motion to dismiss. It dismissed the plaintiffs’ Monell claim against the District with leave to amend and required any amended complaint to be filed no later than February 13, 2025. The order disposed of Docket No. 27.