Estate of Sandra Lee Harmon v. County of San Mateo

Background

The case arises from the fatal police shooting of Sandra Lee Harmon in Half Moon Bay. The officers were San Mateo County deputy sheriffs working as Half Moon Bay police officers under a contract between the county and the city. Sarah Gatliff sued local and county entities on behalf of herself and Harmon’s estate. The complaint asserted two state-law claims and several claims under 42 U.S.C. § 1983, a federal civil-rights statute.

The defendants moved to dismiss the entire complaint on multiple grounds. The plaintiffs acknowledged some deficiencies and requested permission to file an amended complaint.

Issues Discussed

The court said the complaint did not clearly identify whether each claim was brought by Gatliff individually, by the estate, or by both. It explained that Gatliff would need to comply with California’s requirements for bringing claims on behalf of an estate, including providing required documents. The court also noted the possible significance of Harmon’s estranged husband, whom the plaintiffs said might have priority as the estate’s successor in interest.

The court explained that California’s government-claims procedure applies to the state-law claims but not to the § 1983 claims. For the state-law claims, the amended complaint would need to allege facts showing compliance with that procedure or explaining why compliance was excused, separately for each plaintiff.

The court identified possible issues with the individual claims but did not conclusively resolve them. It said the plaintiffs were likely correct that Half Moon Bay could potentially be liable for the county sheriffs’ actions while they worked as city police officers. It also said the excessive-force claim might not be dismissible at this stage based on allegations that officers shot Harmon in the back while she was complying with orders and had her hands over her head. The court said the defendants were likely correct that the family-association claim required allegations showing a heightened purpose to harm, that the complaint lacked enough facts for a municipal-liability claim against the city and county, and that the negligent-training, supervision, and retention claim lacked a statutory basis against those entities.

The court further explained that a § 1983 conspiracy claim is different from a California civil-conspiracy claim and directed the plaintiffs to clarify which type they intended to pursue. It also said the supervisory-liability claim needed clarification about whether it targeted the county sheriff in an official or personal capacity. An official-capacity claim would function as a § 1983 municipal failure-to-train claim; a personal-capacity claim would require allegations of the sheriff’s personal involvement or a specific causal connection to the alleged violation.

Disposition

The court granted the request for leave to amend. It denied the defendants’ motion to dismiss as moot, meaning the court did not decide the motion because the plaintiffs were being allowed to file a new complaint. The amended complaint was due 21 days after the order, and the defendants had 21 days after its filing to respond. The court continued the case-management conference to October 20 at 2 p.m. Judge Vince Chhabria also directed the parties to comply with the stated scheduling and filing requirements.