Guapo-Villegas v. City of Soledad

Background

Martin Guapo-Villegas sued the City of Soledad and Officers Alejandro Castillo and Mustafa Yasin. He alleged federal civil-rights violations under 42 U.S.C. § 1983 and state-law violations arising from his arrest on January 30, 2022. He alleged that the officers falsely reported facts that led to charges for driving under the influence and that those charges were later dismissed by the Monterey County District Attorney.

The amended complaint asserted claims for false arrest, interference with constitutional rights under California Civil Code § 52.1, intrusion into private affairs, unlawful arrest, unlawful search, malicious prosecution under the Fourth and Fourteenth Amendments, and municipal liability against the City. It also sought compensatory damages and punitive damages against the officers. The amended complaint referred to 10 Doe defendants but did not identify their roles or the specific acts supporting claims against them.

Defendants moved to dismiss under Rule 12(b)(6), which tests whether a complaint states a legally sufficient claim, and moved under Rule 12(f) to strike the request for punitive damages. The court had previously dismissed the original complaint while allowing an amendment.

Rulings on Federal Claims

The court dismissed claim 5, alleging that Officer Yasin unlawfully arrested Mr. Guapo-Villegas. Although the court had previously found no probable cause to arrest him for driving under the influence, it concluded that the allegations showed probable cause to arrest him for public intoxication under California Penal Code § 647(f). The court relied on allegations that Mr. Guapo-Villegas was intoxicated, was in a public place, was asleep behind the wheel of a vehicle with its engine running, and had admitted that he was too drunk to drive. The court held that these facts could lead a reasonable officer to find a fair probability that he was unable to exercise due care for his own or others’ safety. Claim 5 was dismissed without leave to amend.

The court dismissed claim 6, alleging that Officer Yasin conducted an unlawful search by coercing Mr. Guapo-Villegas to consent to a breath test. Because the court found probable cause for the public-intoxication arrest, it concluded that requiring a breath test for alcohol intoxication after that lawful arrest did not violate the Fourth Amendment. Claim 6 was dismissed without leave to amend.

The court dismissed claim 9, the municipal-liability claim against the City. Mr. Guapo-Villegas relied on failure-to-train and ratification theories. The court found that allegations concerning a single interaction with the officers did not plausibly show a City policy, practice, or custom that caused a constitutional violation. It also found that the complaint did not identify the policymaker, describe that person’s knowledge, or explain how the person approved the arrest. Claim 9 was dismissed without leave to amend.

The court dismissed claims 7(a) and 8(a), which alleged malicious prosecution under the Fourth Amendment against Officers Yasin and Castillo. The court held that the requirement to attend court, standing alone, generally was not enough to establish the required Fourth Amendment seizure. Claims 7(a) and 8(a) were dismissed without leave to amend.

The court did not decide claims 7(b) and 8(b), which alleged malicious prosecution under the Fourteenth Amendment. The court said it was unclear whether Mr. Guapo-Villegas intended to rely on substantive due process or procedural due process, and whether such a claim is legally available under § 1983. The court ordered Mr. Guapo-Villegas to clarify the legal basis and address whether the claims are recognized under current Supreme Court and Ninth Circuit precedent. Defendants were permitted to file a response.

Other Claims and Disposition

The court deferred consideration of the remaining state-law claims and defendants’ motion to strike the punitive-damages request until after the supplemental briefing on claims 7(b) and 8(b). The court also dismissed the claims against the 10 unidentified Doe defendants without leave to amend because the amended complaint did not provide the required identifying details.

In its conclusion, the court granted in part defendants’ motion to dismiss without leave to amend as to claims 5, 6, 7(a), 8(a), and 9, and deferred decision on the remaining claims until after the supplemental submissions concerning claims 7(b) and 8(b). Judge Virginia K. DeMarchi signed the order.