Cline v. Roberts

Background

David Donald Cline sued Santa Cruz County, Sheriff James Hart, and deputy sheriffs Adam Roberts and Ethan Rumrill. The case arose from a July 15, 2017 welfare check involving Cline and his late mother, Kathryn Cline, at Felton Covered Bridge Park. Kathryn Cline had fallen and injured her hip and head. She repeatedly said that she did not want to go to the hospital. The deputies detained Cline for about 40 minutes, and Roberts later used a taser when Cline turned and reached toward his truck. Cline fell, struck his head, and lost consciousness. He was later cited for elder abuse and resisting, delaying, or obstructing an officer; the criminal charges were eventually dismissed.

Cline asserted claims under 42 U.S.C. § 1983 for prolonged detention, arrest without probable cause, excessive force, and municipal liability under the rule commonly called Monell. He also asserted claims under California’s Bane Act and for common-law assault. Both sides moved for summary judgment, which is a ruling without a trial when the evidence shows no genuine dispute over a fact important to the result.

Preliminary Matters

The court granted Cline’s request for judicial notice of several public criminal-court records. It overruled Cline’s objections concerning alleged destruction or loss of body-camera evidence, the form and relevance of defendants’ evidence, and declarations that Cline argued contradicted deposition testimony. The court concluded that the evidence could be presented in an admissible form at trial and that the alleged inconsistencies did not amount to a fabricated factual dispute.

Cline’s Motion for Summary Judgment

Arrest for elder abuse. The court granted summary judgment for Cline on his claim that defendants lacked probable cause to arrest him for violating California Penal Code § 368(b)(1). The court relied on undisputed facts that the injuries occurred before the deputies arrived, Rumrill did not believe Cline caused the injuries, Kathryn Cline was lucid, and she repeatedly refused medical treatment. The court concluded that no reasonable officer could find probable cause to arrest Cline for elder abuse on these facts.

Arrest for resisting, delaying, or obstructing an officer. The court denied summary judgment on Cline’s claim concerning California Penal Code § 148(a)(1). The parties offered conflicting interpretations of Cline’s conduct during the encounter. The court found that a reasonable jury could credit either the deputies’ account that Cline resisted commands and reached toward his truck or Cline’s account that he cooperated and was attempting to retreat when he was tased.

Excessive force. The court denied summary judgment on Cline’s claim that Roberts used excessive force by deploying the taser. It found disputed facts about whether Cline posed an immediate threat, whether he was resisting or attempting to flee, and whether the taser deployment was reasonable. The court also found it premature to decide the second part of the qualified-immunity analysis—whether the law was clearly established—because the underlying facts remained disputed.

Municipal liability—failure to train. Cline sought judgment against Santa Cruz County on a theory that inadequate training about elder abuse caused the constitutional violation. The court denied summary judgment. The record was unclear about whether Cline was tased while being arrested for elder abuse or while being arrested for resisting, delaying, or obstructing the investigation. Because a reasonable jury could credit either scenario, the court could not decide as a matter of law whether any failure to train was the moving force behind the alleged constitutional violation.

Municipal liability—ratification. The court denied Cline’s request for judgment on his theory that the County ratified the deputies’ conduct. Cline had not shown that Supervisor Ainsworth was a policymaker, and the court found no cited authority establishing that an investigation conducted during litigation could support ratification. The court later granted defendants summary judgment on this theory, however, because Cline’s evidence did not establish the required ratification. Thus, the final order granted defendants summary judgment on the ratification theory and denied it to Cline.

Bane Act and assault. The court denied summary judgment on both Cline’s California Bane Act claim and his common-law assault claim. It concluded that the Bane Act claim depended on the same disputed underlying constitutional violation as the excessive-force claim. It likewise treated the assault claim as corresponding to the excessive-force claim, leaving both claims unresolved.

Defendants’ Motion for Summary Judgment

Prolonged detention. Cline’s lawyer withdrew the Fourth Amendment prolonged-detention claim. The court therefore granted defendants summary judgment on that claim.

Claims against Sheriff James Hart. The court granted defendants summary judgment on all claims against Hart and dismissed him from the case. Cline had sued Hart in his official capacity, but had not alleged or argued that Hart personally participated in the encounter or investigation. The court determined that keeping Hart as a defendant would be redundant because Santa Cruz County was also named.

Probable-cause and excessive-force claims. The court denied defendants summary judgment on the remaining probable-cause and excessive-force claims for the reasons stated in its discussion of Cline’s motion. The claim concerning the elder-abuse arrest was resolved in Cline’s favor; the claim concerning the resisting-officer arrest and the excessive-force claim remained subject to disputed facts.

Monell ratification theory. The court granted defendants summary judgment on the County’s ratification theory. It held that a failure to discipline an officer or an internal review conducted after litigation began was not enough, by itself, to establish ratification.

Bane Act and assault claims. The court denied defendants summary judgment on these claims for the same reasons it denied Cline’s motion on them.

Final Disposition

The court granted in part and denied in part Cline’s motion for summary judgment. It also granted in part and denied in part defendants’ motion. Specifically, Cline obtained summary judgment on the lack-of-probable-cause claim based on elder abuse. Defendants obtained summary judgment on the withdrawn prolonged-detention claim, the Monell ratification theory, and all claims against James Hart. The court denied summary judgment on the resisting-arrest claim, excessive-force claim, Monell failure-to-train theory, Bane Act claim, and assault claim.