Lawson v. City of Arcata

Background

Michelle Charmaine Lawson sued the City of Arcata; former Arcata Police Department Chief Thomas Chapman; Tod Dokweiler; Eric Losey; Krystle Arminio; City Manager Karen Diemer; and unnamed defendants. The lawsuit arose from the April 2017 stabbing and death of Lawson’s son, David Josiah Lawson, who was attending Humboldt State University.

The complaint alleged that Arcata police provided inadequate emergency assistance and conducted an inadequate investigation. Among other allegations, Lawson claimed that officers failed to secure the scene, allowed witnesses to leave without obtaining their information, failed to preserve or collect evidence, and treated the investigation differently from investigations involving Caucasian victims. She also alleged that officials provided inadequate medical attention to David Lawson compared with the treatment of gravely wounded Caucasian people.

Lawson asserted four federal claims: an equal-protection claim under the Fourteenth Amendment through 42 U.S.C. § 1983; a claim concerning allegedly deliberately indifferent policies, practices, customs, training, and supervision under the Fourteenth Amendment and 42 U.S.C. § 1981 through Section 1983; and two conspiracy claims under 42 U.S.C. § 1985(3) and Section 1983. She also asserted four California claims for civil conspiracy, gross negligence, intentional infliction of emotional distress, and negligent infliction of emotional distress.

Legal standard

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. At this stage, the court accepted well-pleaded factual allegations as true and viewed the complaint in the light most favorable to Lawson, but did not accept conclusory allegations or unsupported inferences.

Federal claims

The court held that Lawson sufficiently alleged a race-based constitutional violation. It explained that the Equal Protection Clause protects the right to have police services administered without discrimination and that a Section 1983 claim requires an alleged violation of a federal right by someone acting under state law. The parties did not dispute that the defendants acted under state law for purposes of the alleged conduct.

The court found sufficient Lawson’s allegations that officials treated investigations, emergency medical care, staffing, evidence preservation, and police leadership differently depending on the victim’s race. Those allegations were enough at the pleading stage to support an inference of discriminatory intent. The court therefore denied defendants’ motion to dismiss plaintiff’s federal claims, counts I through IV, for failure to state a claim for a valid race-based constitutional violation. Because the court found the race-based allegations sufficient, it did not address the defendants’ alternative argument concerning a “class-of-one” theory.

State-law claims and immunity

The court concluded that California Government Code sections 821.6 and 815.2(b) provided immunity for the state-law claims arising from the defendants’ allegedly inadequate investigation of David Lawson’s death. It rejected Lawson’s argument that the alleged statements about the investigation came within a fraud exception, finding that the allegations did not show the level of malice needed to avoid immunity.

The order states that the court granted defendants’ motion to dismiss plaintiff’s state-law claims, counts IV through VII, and dismissed those claims with leave to amend. The opinion’s earlier description identifies the four state-law claims as counts V through VIII, so the numbering in the disposition is inconsistent within the text.

Other ruling and disposition

The City had asked the court to consider a declaration from the current police chief, but withdrew that declaration. The court therefore denied as moot the City’s request to consider it.

Overall, the court granted in part and denied in part the defendants’ motion to dismiss. It allowed Lawson’s federal claims to proceed at that stage and allowed amendment concerning the state-law claims if she could allege facts showing that the cited immunity provisions did not apply. The court required an amended complaint by November 8, 2019, or notice by November 1, 2019, if Lawson intended to stand on her existing complaint.