Tran v. Walnut Creek, City of

Background

Quynh Tran alleged that, in December 2024, Sergeant Joseph Coffin and unidentified officers physically restrained her, pushed her against a car, and slammed her to the ground while arresting her. She was arrested for resisting arrest, but the opinion states that no charges were filed. She was then taken to and booked into the County of Contra Costa’s Martinez Detention Facility.

Tran asserted claims under 42 U.S.C. § 1983 against Sergeant Coffin and unidentified defendants. She also asserted a municipal-liability claim under the doctrine from Monell v. Department of Social Services against the City of Walnut Creek, the County, and unidentified defendants. In addition, she asserted state-law claims for negligence, intentional infliction of emotional distress, assault and battery, false arrest, and violations of the Ralph and Bane Acts.

The City answered the complaint. The County moved to dismiss the claims against it, arguing that Tran failed to comply with the California Government Claims Act and failed to adequately plead municipal liability.

State-Law Claims

California law requires a person seeking to sue a public entity on state-law claims to first present a timely claim describing the factual and legal basis for the proposed claims. Tran submitted a claim form to the County in January 2025, within the applicable six-month period. But the form described the arrest and identified Sergeant Coffin and the Walnut Creek Police Department; it did not identify County personnel as involved in the traffic stop or describe the events at the County detention facility as a basis for liability.

The court held that the allegations in Tran’s complaint went beyond the facts in her claim form. Because the claim form did not adequately identify the County’s alleged involvement, the court rejected Tran’s argument that she had substantially complied with the claims law. The court dismissed the state-law claims against the County with prejudice, concluding that amendment would be futile.

Municipal Liability

A municipality may be liable under Monell only when an official policy or custom causes a constitutional violation. Tran alleged that the County maintained a custom, but she did not provide specifics about what the custom was, who participated in it, who knew about it, or how long it had existed. She also alleged no constitutional misconduct beyond her own experience.

The court held that these allegations did not plausibly show a longstanding custom or practice that operated as the County’s standard procedure or that reflected deliberate indifference to constitutional rights. It therefore dismissed Tran’s municipal-liability claim against the County without prejudice.

Disposition

The court granted the County’s motion to dismiss. It dismissed Tran’s state-law claims against the County with prejudice and dismissed her municipal-liability claim against the County without prejudice. The court allowed Tran 28 days from entry of the order to amend the municipal-liability claim to address its deficiencies.