Justice v. City & County of San Francisco
- Edward Chen
- 3:18-cv-05852
- U.S. District Court · Northern District of California
- 3
In Justice v. City & County of San Francisco, Judge Chen granted the City’s motion to stay the civil-rights case pending state criminal proceedings.
The order pauses Melvin Justice’s federal civil-rights case against the City and County of San Francisco, the San Francisco Police Department, and the named police officers while the related state criminal trial is completed.
What happened
Melvin Justice sued San Francisco, its police department, and several police officers under a federal civil-rights law. He alleged that officers unlawfully detained and assaulted him, used excessive force, coerced a blood draw, and committed other misconduct during a September 22, 2016 incident. Justice was representing himself, and a related state criminal case was still pending.
The City asked the federal court to pause the entire civil case, including discovery, until the state criminal proceedings were completed. The City said the criminal case involved overlapping issues, including Justice’s alleged reckless driving, driving under the influence, and resisting or obstructing a police officer. Justice did not oppose the motion.
The court granted the City’s motion to stay and paused the case until completion of the trial in the state criminal case. Judge Edward Chen also canceled the motion hearing and the January 30, 2020 status conference, rescheduling the matter for February 27, 2020, with a joint status report due February 20, 2020.
The detailed version
- Justice v. City & County of San Francisco · No. 3:18-cv-05852
- Edward Chen
- Jan. 6, 2020
Background
Melvin Justice, Jr., representing himself, brought a civil-rights action under 42 U.S.C. § 1983 against the City and County of San Francisco, the San Francisco Police Department, and various police officers employed by the department. He alleged that, during an incident on or about September 22, 2016, officers unlawfully detained him, unlawfully administered a field sobriety test, subjected him to cruel and unusual punishment, physically assaulted him, coerced him into a blood draw, and used excessive force.
At an earlier case-management conference, the City informed the court that a state criminal action against Justice was pending based on the same events. The City reported that the criminal trial had been continued to February 10, 2020 and that the criminal and civil cases involved overlapping issues. The court had previously paused the federal case until the next status conference.
Motion and analysis
The City moved for a complete stay of the federal case, including discovery, until the state criminal proceedings were completed. Justice did not file an opposition.
The court relied on Wallace v. Kato and Keating v. Office of Thrift Supervision. Those decisions allow a federal civil case to be paused when related criminal proceedings may address overlapping factual issues. The court considered that Justice’s allegations of unlawful detention and excessive force were likely to be addressed in the state criminal case, which included charges of reckless driving, driving under the influence, and resisting or obstructing a police officer.
Ruling
The court granted the City’s motion to stay. Proceedings in the federal case were stayed pending completion of the trial in the state criminal case. The hearing on the motion was vacated. The court also vacated the January 30, 2020 further status conference and continued the matter to February 27, 2020, at 10:30 a.m.; the parties were ordered to file a joint status-conference statement by February 20, 2020. The order disposed of Docket No. 32.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.