Reid v. City Of Oakland

Background

LaJuana A. Reid sued the City of Oakland, the Oakland Police Department, the Estate of Moses Jacko Jr., and named Oakland police personnel sued in their official capacities. Reid alleged earlier harassment beginning in 1999 and focused her complaint on events from August 2, 2019, through October 1, 2019. She alleged that she reported activity at a neighboring property, that police officers and others created or relied on false reports and emergency calls, and that officers took her into custody on October 1, 2019 in what she called a staged administrative kidnapping.

Reid asserted claims under 42 U.S.C. § 1983, a federal civil-rights statute, including claims against the City under the rule commonly called municipal liability. She also asserted state-law claims including intentional infliction of emotional distress, false imprisonment, malicious prosecution, defamation, civil conspiracy, claims under California’s Bane Act and Ralph Act, negligent supervision and retention, failure to intervene, trespass, and other claims. She also invoked the Federal Kidnapping Act, 18 U.S.C. § 1201, and asserted claims involving false police reports and false 911 calls.

Motion to Dismiss

The City moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The court accepted the complaint’s factual allegations as true for purposes of the motion and construed Reid’s self-represented pleadings liberally.

The court held that Reid’s § 1983 claims were subject to California’s two-year personal-injury limitations period and were barred because they arose from events before January 10, 2023, while the initial complaint was filed on January 10, 2025. The court likewise held that her intentional-infliction-of-emotional-distress claim was time-barred. It determined that false-imprisonment and defamation claims based on the 2019 events were also untimely under California’s one-year limitations period.

The court further ruled that Reid had not alleged a favorable termination needed for her malicious-prosecution claim and that, insofar as that claim relied on the 2019 events, it was time-barred. It held that her civil-conspiracy claim was time-barred to the extent it was based on § 1983. The court also treated the Bane Act, Ralph Act, negligent-supervision, failure-to-intervene, trespass, and alleged bodily-integrity or unlawful-search claims as untimely or inadequately stated for the reasons discussed in the opinion.

The court rejected Reid’s arguments for equitable tolling, which can extend a filing deadline in limited circumstances, because her allegations did not show that she was unaware of the relevant injuries or that extraordinary circumstances prevented timely filing. The court also rejected her reliance on the continuing-violations doctrine because she did not sufficiently allege ongoing violations after October 2019 or adequately connect the earlier alleged harassment to the 2019 events.

The court dismissed the Federal Kidnapping Act claim because federal criminal statutes generally do not create a private right to sue. It also found that the claims concerning the filing or use of false police reports and the allowance of false 911 calls and coached narratives did not provide sufficient legal or factual details. To the extent those claims relied on California criminal statutes, the court stated that Reid could not assert civil liability based on those alleged violations.

Leave to Amend and Disposition

Reid separately sought permission to file a third amended complaint adding John Jack Romero as a defendant in his individual capacity, in addition to his official-capacity status. The court granted that request, finding no bad faith, undue delay, prejudice, or futility. The court also granted the motion to dismiss and dismissed Reid’s complaint with leave to amend.

Reid may file a third amended complaint within 21 days, solely to add Romero in his individual capacity and cure the deficiencies identified in the order. The court stated that the motion for leave to amend at ECF No. 45 was moot and continued the case-management conference to November 4, 2025.