Doe v. County of Sonoma

Background

John Doe, proceeding without a lawyer and suing under a pseudonym, alleged civil-rights violations arising from an involuntary psychiatric hospitalization in December 2015. The hospitalization occurred under California’s Lanterman-Petris-Short Act, which permits an initial detention of up to 72 hours when there is probable cause to believe that a person, because of a mental disorder, is dangerous to others, dangerous to himself or herself, or gravely disabled. The detention can be extended for up to 14 days after an additional evaluation and certification.

Doe alleged that he was hospitalized after reports that he had schizophrenia and had threatened “suicide by cop.” He characterized those reports as anonymous hearsay and said they did not establish probable cause. He requested a certification hearing, and the hearing officer found probable cause. He then requested judicial review through a writ proceeding and gave a completed form to a hospital employee. According to the complaint, the form was logged in his medical chart and the Sonoma County Patient Advocate’s Office was notified, but the form was never filed in California superior court. Doe was discharged after approximately eight days.

Doe asserted state and federal claims against Sonoma County, county employees and the Department of Health Services, the State of California, and the California Department of Justice and Attorney General. His federal claims under 42 U.S.C. § 1983 alleged violations of the Fourth Amendment protection against unreasonable seizures and the Fifth Amendment right to due process. He sought damages, an injunction, and a declaration that the Lanterman-Petris-Short Act was unconstitutional. He also mentioned a restriction on his ability to possess firearms but did not identify a specific claim for relief based on it.

After filing this case, Doe filed a related lawsuit against Danielle Santos, whom he said was in charge of the medical facility where he was evaluated. That lawsuit asserted negligence, false imprisonment, an unspecified constitutional violation under Section 1983, and a claim against Sonoma County for failure to train Santos. Because Doe was representing himself, the court treated that complaint as an amendment to this case and ordered the related lawsuit closed administratively.

Motions to dismiss

The defendants moved to dismiss under Rules 12(b)(1) and 12(b)(6). Rule 12(b)(6) tests whether a complaint alleges enough facts to state a legally plausible claim; Rule 12(b)(1) concerns the court’s authority to hear a claim. The court accepted factual allegations as true for purposes of the motions but did not accept bare legal conclusions or unsupported deductions.

California state defendants

The court dismissed the claims against the California state defendants with prejudice. It held that the Eleventh Amendment barred Doe’s claims for money damages under Section 1983 against those defendants. It also held that the state entities were not “persons” subject to Section 1983, except in limited circumstances involving prospective injunctive relief.

The court concluded that this exception did not save Doe’s claims because the alleged event began and ended in 2015, and Doe did not plausibly allege facts supporting prospective injunctive relief. The complaint also did not allege facts showing that the Attorney General or another state actor was meaningfully connected to the events. The court stated that amendment would not overcome these barriers.

Sonoma County defendants

The court dismissed the claims against the county defendants with leave to amend. It explained that a local government can be liable under Section 1983 only when a government policy or custom causes the injury. Doe alleged at most one short-term incident affecting him in 2015, not a pattern, practice, or custom sufficient to support liability against the county entities.

The court reached the same conclusion about the failure-to-train claim from the related lawsuit. It said that a failure-to-train theory ordinarily requires a pattern of similar constitutional violations by untrained employees, and Doe had not alleged such a pattern. Unlike the claims against the state defendants, the court could not say that further amendment of the county-related claims would necessarily be futile.

Challenge to the Lanterman-Petris-Short Act

The court understood Doe to be challenging the Act’s constitutionality on due-process grounds. His theories appeared to be that the Act improperly required patients to take affirmative steps to request a certification review hearing or file a writ application, and that the statute stigmatized patients as mentally ill while living in society.

The court held that neither theory plausibly alleged a due-process violation. It pointed to the certification hearing, the availability of a writ application, and the notification of a patient advocate. The court nevertheless dismissed this constitutional claim with leave to amend because it was not certain at that stage that amendment would be futile.

State-law claims and disposition

The court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims alongside federal claims—while no plausible Section 1983 claim remained. The order states that the complaint was dismissed. Doe could file an amended complaint addressing the claims against the county defendants and the constitutionality of the Lanterman-Petris-Short Act by October 18, 2019. He could not add new claims or parties. If he did not amend, the case would be dismissed with prejudice under Federal Rule of Civil Procedure 41(b).