Sanchez v. City Of San Jose

Background

Defendants moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The opinion addresses claims against Chief Garcia and the City of San Jose arising from an October 2019 incident. The opinion also notes that Sanchez agreed to dismiss the Seventh Claim under the Bane Act against Chief Garcia. The excerpt does not provide the details of the incident or fully identify the parties described as “et al.”

Chief Garcia

The court dismissed all claims against Chief Garcia. It dismissed the First, Second, and Third Claims because the complaint did not allege that Chief Garcia was involved in the October 2019 incident. The court also held that Section 1983 does not impose liability on a supervisor merely because the supervisor oversees other people.

Sanchez agreed to dismiss the Seventh Claim under the Bane Act against Chief Garcia, which resolved that issue. The opinion contains an incomplete sentence referring to defendants’ mention of dismissal of “Count Eight,” so the excerpt does not establish the court’s ruling on that count.

City of San Jose

The court dismissed the Section 1983 claims against San Jose. It found that the complaint did not plausibly allege a pattern or practice showing deliberate indifference to Sanchez’s constitutional rights. The other incidents listed in the complaint were not meaningfully connected to Sanchez’s incident and did not establish the required causal link between a city policy or custom and the alleged constitutional violation.

The court also rejected the failure-to-train theory because the complaint did not allege facts showing deliberate indifference through a pattern of similar violations. It rejected the ratification theory because the allegations that an authorized decisionmaker adopted and approved the alleged misconduct were conclusory and unsupported by facts.

The court dismissed the Fourth, Fifth, and Sixth Claims against San Jose. It dismissed the Bane Act claim in the Seventh Claim against San Jose because the complaint did not plausibly state such a claim against the city. It also dismissed the Ninth Claim alleging an Americans with Disabilities Act violation against San Jose because Sanchez did not allege a disability within the statutory definition; stating only that he suffered from seizures was not enough, without additional facts.

Disposition

The motion to dismiss was granted and denied in part. The court denied the motion in all other respects. Leave to amend the claims against Chief Garcia and San Jose was granted, and Sanchez could file an amended complaint by August 5, 2021. The amended complaint could not add new claims or parties without the court’s prior approval. The court stated that failure to amend by the deadline would result in dismissal with prejudice of the pertinent claims under Rule 41(b).