Mattingly v. Jurek

Background

Michael Joseph Mattingly, representing himself, sued Jaqueline Jurek, Tyler Knapp, Trevor Morgan, Gabe McKenna, Joe Walters, and Armondo Quintero. The defendants were employed with the California Department of Parks and Recreation. Mattingly alleged that he was performing protest music at Twin Lakes Beach in Santa Cruz on July 30, 2022, when Jurek, Knapp, and Morgan approached him, said they had a warrant for his arrest, and arrested him after he demanded to see the warrant. He sought compensatory damages and declaratory and injunctive relief.

The First Amended Complaint asserted four causes of action: a First Amendment retaliation claim under 42 U.S.C. § 1983 against Jurek, Knapp, and Morgan; a Fourth Amendment unlawful-arrest claim under § 1983 against those officers; a conspiracy claim under 42 U.S.C. § 1985 against those officers; and a claim under Sections 2 and 3 of Article I of the California Constitution against Quintero, McKenna, and Walters.

Judicial Notice

The court granted defendants’ requests for judicial notice. It took notice that a bench warrant had been issued for Mattingly on September 13, 2021, by Judge Vinluan of the Superior Court of Santa Cruz, and took notice of the documents’ authenticity. It did not take notice of other facts contained in those documents, including the truth of any facts supporting the warrant.

Legal Standard

The court applied Federal Rule of Civil Procedure 12(b)(6), which requires dismissal when a complaint does not allege enough facts to state a legally plausible claim for relief. The court accepted factual allegations as true for purposes of the motion but did not accept conclusory allegations or unreasonable inferences.

Rulings

The court allowed defendants to raise arguments in the second motion to dismiss even though they had not raised some of them in the first motion. The court noted that defendants had not filed an answer and could otherwise have raised the same failure-to-state-a-claim defenses later.

Claims Against Quintero

The court held that the Eleventh Amendment protected Quintero from suit on the claims asserted against him. The court had previously determined that Mattingly sued Quintero in his official capacity, and the First Amended Complaint did not allege particular conduct sufficient to sue him in his individual capacity. The court therefore granted defendants’ motion to dismiss the claims against Quintero and stated that those claims were dismissed without leave to amend.

Claims Against the Officers

The court held that Jurek, Knapp, and Morgan were entitled to qualified immunity. Qualified immunity protects an official when the alleged conduct did not violate a clearly established constitutional or statutory right that a reasonable person would have understood.

The court reasoned that the existence of the September 13, 2021 bench warrant supported the officers’ reasonably arguable belief that they were arresting Mattingly under a valid warrant. The court also concluded that the officers were not unreasonable in failing to produce a physical copy of the bench warrant. It rejected Mattingly’s reliance on authorities concerning search warrants and other types of arrest warrants, and noted that the cited California statute allowed an officer with a warrant abstract to proceed as if the officer possessed the original warrant.

The court granted defendants’ motion to dismiss claims one, two, and three against the officers based on qualified immunity. It dismissed those claims without leave to amend because further amendment would be futile.

State-Law Claims and Disposition

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over the remaining state-law claims against Quintero, McKenna, and Walters. Supplemental jurisdiction is the court’s authority to hear related state-law claims alongside federal claims. The court stated that the state-law claims were dismissed without prejudice to Mattingly’s ability to pursue them, as appropriate, in a state court action.

In its conclusion, the court ordered that the motion to dismiss was granted in part. It stated that all claims against Quintero were dismissed without leave to amend and with prejudice; claims one, two, and three against the officers were dismissed without leave to amend and with prejudice; and all state-law claims against Quintero, McKenna, and Walters were dismissed without prejudice after the court declined supplemental jurisdiction. The court dismissed the case and directed the Clerk to close the file.