Williams v. City of Pleasanton

Background

Ellen Williams, also known as Ellen Girma, sued two groups of defendants after her November 14, 2019 arrest at ValleyCare Medical Center in Pleasanton. The defendants were the City of Pleasanton, the Pleasanton Police Department, four Pleasanton police officers, and six medical-center nurses or doctors. Williams alleged that hospital staff provided police with false information, including an accusation by Arianna Welch Frangieh that Williams pushed her. Williams further alleged that officers grabbed and slammed her to the floor, handcuffed her, forced her to stand, and injured her during transport to jail.

Williams alleged that she was charged with resisting arrest based on fabricated accounts by officers and that the district attorney later dismissed the criminal case with prejudice. Her complaint asserted claims under 42 U.S.C. § 1983, which allows suits for certain constitutional violations by state actors, as well as claims for negligence, false arrest or false imprisonment, battery, violation of California’s Ralph Act and Bane Act, negligent hiring or supervision, and malicious prosecution.

Motions to Dismiss

The two groups of defendants moved to dismiss. A motion to dismiss tests whether a complaint adequately states legally permitted claims based on the allegations in the complaint. The court granted the motions. It explained that Williams could not use new factual allegations in a declaration to cure defects in the complaint, although it allowed amendment of claims that might be corrected with additional allegations.

Pleasanton Defendants

The court declined to dismiss the Pleasanton Police Department merely because its presence alongside the City was duplicative. Williams could continue naming both entities as defendants.

The court dismissed the Second Cause of Action, the municipal-liability claim commonly called a Monell claim, with leave to amend. Williams had alleged generally that the City and Police Department maintained customs or policies involving false arrests, false imprisonment, excessive force, and unequal treatment, but she identified no facts showing a pattern of similar violations or facts supporting failure to train, failure to discipline, or ratification. The court allowed her to amend by identifying the specific theory of municipal liability and supporting facts.

The court dismissed the Ninth Cause of Action for negligent hiring, supervision, training, or discipline with prejudice because Williams did not address the claim or identify a basis for amending it.

The court dismissed the Seventh Cause of Action under California Civil Code section 51.7, the Ralph Act, with leave to amend. Williams needed to identify violence or threats of violence by each defendant based on race, gender, or another protected classification.

The court dismissed the Fourteenth Amendment portion of the First Cause of Action with leave to amend because the complaint did not allege that each officer treated Williams differently because of race, gender, or another protected classification.

VCMC Defendants

The court granted leave to amend so Williams could allege the basis for federal jurisdiction over her state-law claims against the medical-center defendants.

The court dismissed the Sixth Cause of Action for battery against Frangieh with leave to amend because Williams had not adequately alleged what acts by Frangieh constituted battery. Williams had agreed that the battery claim against the other medical-center staff should be dismissed, and those claims were dismissed with prejudice.

The court dismissed the VCMC-related Ralph Act claim with leave to amend. It also dismissed the Eighth Cause of Action under California Civil Code section 52.1, the Bane Act, with leave to amend. Williams needed to allege what each medical-center defendant did to interfere, or attempt to interfere, with her legal rights through threats, intimidation, or coercion.

The court dismissed the Tenth Cause of Action for malicious prosecution with leave to amend. Williams needed to allege that a criminal case had been filed, identify the acts by each medical-center defendant that directed the prosecution, and plead facts showing lack of probable cause, malice, and that the defendants sought out authorities and falsely reported specific criminal conduct.

The court also dismissed the Fifth Cause of Action for false imprisonment against Frangieh with prejudice.

Disposition

The order granted the motions to dismiss. The Fourteenth Amendment claim, Monell claim, battery claim against Frangieh, Ralph Act claim, Bane Act claim, and malicious-prosecution claim were dismissed with leave to amend. The false-imprisonment claim against Frangieh, the battery claims against the other medical-center staff, and the negligent hiring, supervision, training, or discipline claim were dismissed with prejudice. Williams was required to file an amended complaint by September 29, 2021. Judge William H. Orrick signed the order.