Matthews v. County of Santa Cruz

Background

Darin Matthews sued the County of Santa Cruz; Steven Carney; the City of Scotts Valley; four identified Scotts Valley police officers—Wayne Belville, Michael Birley, Michael Neronde, and Paul Lopez—and twenty unknown city officers, agents, or employees. The county defendants separately answered the complaint; the motion addressed in this order was filed by the city defendants.

Matthews alleged that on February 19, 2019, Scotts Valley officers stopped him while he was driving, searched his person, searched his vehicle and belongings, transported him to his home, and searched the home. He alleged that the officers did not identify the real reason for the stop, did not obtain his permission for the searches, and found nothing unlawful in his vehicle. He also alleged that Carney told him there was a warrant to search his home and gave a vague explanation for the search.

Matthews asserted six causes of action against the city defendants: federal unreasonable-search-and-seizure claims under 42 U.S.C. § 1983; a municipal-liability claim against the City of Scotts Valley under the rule from Monell v. Department of Social Services; a claim under the search-and-seizure provision of the California Constitution; assault and battery; intentional and/or negligent infliction of emotional distress; and a claim under California Civil Code section 52.1, known as the Bane Act.

Legal standard

The court applied Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. Under the pleading standard described in Twombly and Iqbal, a complaint must provide enough factual content to give defendants fair notice and allow a reasonable inference that each defendant is liable. The court accepted the background facts as Matthews alleged them for purposes of deciding the motion.

Federal claims against individual city officers

For a claim under § 1983, a plaintiff must allege that a defendant acting under state law caused a violation of federal rights. The court emphasized that § 1983 does not impose liability merely because someone supervises another person or works for the same government entity. The allegations must connect each individual defendant to specific conduct.

The court found that Matthews used “OFFICERS” and “officers” inconsistently. The terms sometimes appeared to refer to the four identified officers, sometimes to other officers, and possibly at times to Carney. The complaint also named twenty unknown city officers without clearly distinguishing them from the other officers. Because the complaint did not identify what each city defendant allegedly did, it did not give the defendants fair notice or allow the court to assess each person’s liability.

The court therefore granted the motion to dismiss the § 1983 claims against the four identified city officers, with leave to amend. For the same reason, it granted with leave to amend the motion to dismiss the § 1983 claims against the twenty unknown city officers, agents, or employees.

The court separately held that the City of Scotts Valley could not be held liable under § 1983 merely in a supervisory or employer-responsibility role. It granted the motion to dismiss the first cause of action against the City without leave to amend on that theory.

Municipal-liability claim

Matthews’s second cause of action asserted that the City was liable under Monell based on policies, customs, practices, or inadequate training or supervision. The court explained that a municipality may be liable under § 1983 when an official policy, longstanding custom, or final policymaker causes a constitutional violation. An isolated incident ordinarily is not enough to establish a longstanding custom or practice.

The court found that Matthews had not alleged enough facts to support the existence of the required policy, custom, or practice. His argument relied on the alleged involvement of four city officers in one incident, but the court stated that one isolated incident was insufficient. The court granted the motion to dismiss the Monell claim with leave to amend.

California Constitution claim

Matthews alleged that the city defendants violated Article I, section 13 of the California Constitution. The court noted that Matthews did not address the legal framework for determining whether that provision creates a damages remedy and appeared to concede the claim by leaving the defendants’ argument unanswered. The court granted the motion to dismiss this claim with leave to amend.

Assault and battery

Matthews alleged that the city defendants’ conduct during his detention constituted assault and battery. The court found that he appeared to concede these claims because he did not respond to the argument that the complaint alleged insufficient facts. The court granted the motion to dismiss these claims with leave to amend.

Emotional-distress claims

Matthews alleged intentional and/or negligent infliction of emotional distress based on the search of his home. The city defendants argued that he had not alleged facts showing the required conduct or mental state. Matthews did not respond to that argument and stated that the city defendants could disregard claims based on their participation in the home search if they showed that the warrant was facially valid. The court found that he had effectively conceded these claims and granted dismissal with leave to amend, regardless of whether the defendants could produce the warrant.

Bane Act claim

The Bane Act allows a person to seek damages or injunctive relief when threats, intimidation, or coercion interfere with federal or state rights. The court explained that the complaint did not clearly identify which city defendants participated in the alleged violations and did not provide enough facts to evaluate their purpose or intent. The court granted the motion to dismiss the section 52.1 claims with leave to amend.

Disposition

The court granted the city defendants’ motion to dismiss in full. It allowed Matthews to file an amended complaint in accordance with the order by March 23, 2021, while specifying that the supervisory-liability claim against the City in the first cause of action was dismissed without leave to amend.