Mattingly v. Jurek

Background

Michael Joseph Mattingly, who represented himself, sued six named defendants connected with the California Department of Parks and Recreation. He alleges that, while singing protest music near Twin Lakes Beach in Santa Cruz, California, Officers Jaqueline Jurek, Tyler Knapp, and Trevor Morgan approached and surrounded him, claimed they had a bench warrant for his arrest, failed to produce the warrant when he asked to see it, searched him, and arrested him.

The complaint asserted seven claims: a constitutional unlawful-arrest and search claim under 42 U.S.C. § 1983; a due-process and false-imprisonment claim under § 1983; a First Amendment claim under § 1983; a malicious-prosecution claim; a conspiracy claim under 42 U.S.C. § 1985; a claim under the California Constitution; and a § 1983 supervisory-liability claim. The defendants moved to dismiss, and Mattingly moved to strike the dismissal motion.

Motion to Strike

The court denied Mattingly’s motion to strike. Mattingly argued that he had submitted his dispute through an administrative process and that the Department had not responded within the 45-day period under the California Government Claims Act. The court explained that the Act requires a claimant to present a claim for administrative resolution before suing, but it does not prevent the government from opposing the lawsuit after it is filed. The court also found no legal support for Mattingly’s remaining arguments about striking the dismissal motion.

Because Mattingly represented himself, the court nevertheless considered arguments he raised in his motion-to-strike briefing when evaluating the motion to dismiss.

Dismissal Standards

The defendants primarily moved under Federal Rule of Civil Procedure 12(b)(6), which requires dismissal when a complaint does not state a legally sufficient claim. At this stage, the court generally accepts well-supported factual allegations as true and draws reasonable inferences in the plaintiff’s favor, but it need not accept conclusory allegations or unreasonable inferences. If claims are dismissed, the court may allow amendment unless amendment would be futile, cause undue prejudice, or be sought in bad faith.

Claims Against Officers Jurek, Knapp, and Morgan

The officers argued that qualified immunity protected them from liability on Claims One, Two, Three, and Six. Qualified immunity can protect government officials from damages claims when the law did not clearly establish that their alleged conduct was unlawful. The officers argued that the alleged existence of an arrest warrant would have informed reasonable officers that they had probable cause to arrest Mattingly.

Mattingly did not meaningfully respond to that argument in opposition to the motion to dismiss. The court treated his limited response as a waiver of opposition to the qualified-immunity argument. Without deciding the merits of the qualified-immunity defense, the court dismissed Claims One, Two, Three, and Six as asserted against Jurek, Knapp, and Morgan, with leave to amend.

The officers also argued that the malicious-prosecution claim failed because Mattingly did not overcome the presumption that a prosecutor independently decided to bring a case against him. Mattingly did not address that argument. The court therefore treated his opposition as waived and dismissed Claim Four, the malicious-prosecution claim, with leave to amend, without deciding the merits of the defendants’ argument.

Claims Against Quintero

Defendant Armondo Quintero invoked immunity under the Eleventh Amendment for Claims Three and Seven. The Eleventh Amendment generally protects states from suits brought by citizens in federal court, and the court explained that this protection extends to the Department and to Department employees sued in their official capacities.

Although Mattingly stated that he sued Quintero in his individual capacity, the court looked at the substance of the allegations. Because Mattingly alleged that Quintero implemented policies, practices, and customs that violated his constitutional rights, the court concluded that the allegations implicated Quintero’s official capacity. The court rejected Mattingly’s arguments that administrative notices or his characterization of the suit prevented Quintero from asserting the defense.

The court dismissed Claims Three and Seven to the extent they were asserted against Quintero, with leave to amend. The court did not extend the Eleventh Amendment defense to Claim Six because Quintero had raised that defense only as to Claims Three and Seven.

Supervisory-Liability Claims

Defendants Gabe McKenna and Joe Walters sought dismissal of the supervisory-liability claim. Under § 1983, a supervisor may be liable based on personal involvement in a constitutional violation or a sufficient causal connection between the supervisor’s wrongful conduct and the violation.

Mattingly did not respond to this argument in his opposition to dismissal. In his other briefing, he argued that notices he served on the Department should have been communicated to the arresting officers. The court found that, without additional facts, it was speculative whether communicating the notices would have prevented the arrest. The court therefore dismissed Claim Seven as asserted against McKenna and Walters, with leave to amend.

Claims Remaining and Disposition

The court concluded that the defendants had not provided a basis for dismissing Claim Five, the conspiracy claim against Jurek, Knapp, and Morgan, or Claim Six to the extent it was asserted against Quintero, McKenna, and Walters. Those portions survived dismissal.

The court’s final order denied the motion to strike and granted in part and denied in part the motion to dismiss, with leave to amend. It dismissed Claims One, Two, Three, Four, and Seven. Claim Five survived dismissal, and Claim Six survived dismissal to the extent asserted against Quintero, McKenna, and Walters. The court gave Mattingly until February 26, 2025, to file an amended complaint; otherwise, it would schedule an initial case-management conference.