Ramachandran v. City of Los Altos

Background

Satish Ramachandran sued the City of Los Altos and Los Altos employees under 42 U.S.C. § 1983, alleging violations of his First Amendment rights and his Fourteenth Amendment right to equal protection. His allegations concerned the city’s handling of permits, building-code enforcement, notices, a search of his property, and a misdemeanor prosecution related to removing one of those notices. He alleged that Los Altos and its employees treated him and other non-white residents differently from white residents.

The operative third amended complaint asserted First Amendment and equal-protection claims against Kirk Ballard and David Kornfield, and a municipal-liability claim against Los Altos. Municipal liability under the rule commonly called Monell liability allows a claim against a local government based on an alleged policy, custom, or practice that caused a constitutional violation.

Ramachandran sought permission to file a fourth amended and supplemental complaint. The proposed pleading would add City Manager Chris Jordan; Best Best & Krieger LLP and its attorneys Christopher Diaz and Christina Hickey; and neighbor Pamela Jacobs. It would also split the existing Monell claim into two claims, add a civil Racketeer Influenced and Corrupt Organizations Act claim, and add a state-law claim for intentional infliction of emotional distress.

Court’s analysis

The court first rejected Ramachandran’s reliance on Federal Rule of Civil Procedure 15(b). That rule permits amendments to conform pleadings to evidence presented during or after trial, but no trial had occurred. The court therefore denied the motion to amend under Rule 15(b).

The court also denied the request to supplement the complaint under Rule 15(d). That rule concerns events occurring after the pleading being supplemented. The proposed allegations did not concern events occurring after the third amended complaint was filed on March 18, 2019, and Ramachandran did not dispute that point.

The court then considered amendment under Rule 15(a)(2), which generally favors allowing amendments when justice requires. The court found that Ramachandran knew most of the facts supporting his proposed amendments when he filed the third amended complaint and waited nearly a year to seek further amendment. The case had already had two trial-date continuances, and the proposed new claims and defendants would require additional discovery.

The court concluded that adding the two Monell claims and Chris Jordan would not require additional discovery or disrupt the trial schedule. It therefore found no substantial prejudice from those amendments. The court also found that defendants had not shown that any proposed amendment would necessarily fail as a matter of law, and it did not find bad faith.

The court reached a different conclusion regarding the proposed RICO and emotional-distress claims and the proposed addition of Best Best & Krieger LLP, Christopher Diaz, Christina Hickey, and Pamela Jacobs. Those claims were distinct from the existing claims and would require new defendants to challenge the allegations and conduct additional discovery, including reopening depositions and continuing the trial. The court found that these additions would substantially delay the case and prejudice the defendants.

Disposition

The court granted in part and denied in part the motion for leave to file a fourth amended and supplemental complaint. It permitted Ramachandran to file a fourth amended complaint containing the two Monell claims and adding Chris Jordan as a defendant on the § 1983 claims. It allowed related factual allegations to the extent they concerned those permitted claims.

The court denied the motion as to the proposed civil RICO claim, the state-law intentional-infliction-of-emotional-distress claim, and Best Best & Krieger LLP, Christopher Diaz, Christina Hickey, and Pamela Jacobs. Ramachandran was ordered to file the permitted fourth amended complaint by April 27, 2020. Judge Virginia K. Demarchi signed the order. The ruling addressed permission to amend the pleadings and did not decide the ultimate merits of the underlying constitutional claims.