Greene v. City of San Francisco

Background

Quinci Greene, proceeding without a lawyer, sued the City and County of San Francisco (CCSF), the San Francisco Main Library, unidentified Library Security officers, and unidentified San Francisco Sheriff’s Office deputies. He alleged that on September 4, 2024, Library Security officers told him to leave the library because of a suspension that he says had expired. He alleged that, as he walked toward the exit, Library Security officers and sheriff’s deputies pushed him against a wall, punched him, detained him, and later took him to jail. He also alleged that he was subjected to a COVID test, a visual strip search, and detention without being brought before a judge or told of charges. He said he was released on September 6, 2024, and that no charges were filed.

The second amended complaint asserted nine causes of action: excessive force, unlawful seizure and false arrest, an unconstitutional strip search, a Fourteenth Amendment due-process violation, assault and battery, false imprisonment, negligence, a claim under California’s Bane Act, and municipal liability under 42 U.S.C. § 1983. The municipal-liability claim was brought only against CCSF; most other claims were directed at unidentified individual defendants.

Early Discovery

The court had previously allowed limited early discovery so Greene could identify the unidentified defendants. It ordered CCSF to provide incident reports concerning the September 4, 2024 incident. CCSF submitted reports that identified Library Security officers, sheriff’s deputies, and officers involved in searching, transporting, and booking Greene. Greene acknowledged receiving the reports but argued that they did not provide enough information. He requested additional early discovery.

The court denied that request. It concluded that CCSF had provided sufficient information to make identification of the unidentified defendants possible.

Motion to Dismiss

CCSF moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim for relief. The court applied the requirement that a complaint allege enough facts to make the claim plausible, while accepting factual allegations as true for purposes of the motion.

Greene’s municipal-liability claim was based on Monell v. Department of Social Services. A Monell claim seeks to hold a municipality liable under § 1983 for a constitutional violation caused by the municipality’s policy, custom, or deliberate-indifference-based failure to train, rather than merely by the acts of its employees.

Greene alleged that CCSF had an unofficial policy or custom allowing Library Security officers to use force based on invalid or pretextual suspension claims. He also alleged a pattern of harassment and discrimination against him from 2021 through September 2024 and asserted that CCSF failed to train employees on verifying suspensions, constitutional limits on force, and related matters.

The court ruled that these allegations were conclusory and did not provide enough supporting facts. In particular, Greene did not provide details showing that the prior incidents were similar to the alleged use of force or involved invalid library suspensions. The court therefore dismissed the Monell claim against CCSF without leave to amend.

The court also addressed any other claims brought against CCSF and stated that they were properly dismissed because Greene filed no opposition to the motion. Separately, Greene had failed to identify the individual defendants even though the court determined that he had received information sufficient to do so. Combined with his failure to oppose the motion, the court treated this as failure to prosecute and dismissed the remaining claims without prejudice.

Disposition

The court denied Greene’s motion for leave to conduct early discovery. It dismissed the Monell claim against CCSF without leave to amend and dismissed the remaining claims without prejudice for failure to prosecute.