Anglero-Wyrick v. County of Sonoma

Background

Jason Anglero-Wyrick filed a First Amended Complaint against the County of Sonoma, Jeremy Jucutan, Nikko Miller, and Mark Essick. The defendants moved to dismiss only the amended claims for malicious prosecution and municipal liability based on ratification.

According to the amended complaint, the Sonoma County District Attorney’s Office filed a felony complaint against Anglero-Wyrick before prosecutors reviewed body-worn-camera videos of the events. The complaint alleged that deputies, including Jucutan and Miller, intentionally included false, misleading, or exaggerated information in their reports to persuade prosecutors to bring criminal charges. After prosecutors reviewed video evidence that allegedly exposed the reports as false, the criminal case was dismissed.

The amended complaint also alleged that Essick, identified as the County’s Sheriff and final policymaker, ordered an administrative investigation into Jucutan’s and Miller’s conduct. The investigation concluded that Jucutan’s use of a police dog and force against Anglero-Wyrick, and Miller’s use of a taser and force, were within law and policy. It recommended that both deputies be exonerated, and the complaint alleged that Essick adopted those findings and approved the deputies’ conduct.

Malicious-Prosecution Claim

For a malicious-prosecution claim under 42 U.S.C. § 1983, a plaintiff must allege, among other things, that defendants prosecuted him maliciously and without probable cause, for the purpose of denying equal protection or another specific constitutional right, and that the criminal proceedings ended in his favor.

The court had previously dismissed this claim because Anglero-Wyrick had not alleged that the deputies withheld relevant information, provided false information, or pressured the district attorney to bring charges. In the amended complaint, he alleged that the deputies wrote false reports to deceive the district attorney into initiating criminal proceedings. The court held that these new allegations were sufficient to state a malicious-prosecution claim and denied the defendants’ motion on this ground.

Essick

Anglero-Wyrick sued Essick in his official capacity. An official-capacity suit is another way of pleading a claim against the government entity represented by the official. Because the County was also named as a defendant, the court treated the claim against Essick as redundant and granted the defendants’ motion on this ground. The court dismissed Essick as a defendant.

County Ratification Claim

A municipal-liability claim under Monell v. Department of Social Services based on ratification requires allegations that the municipality’s final policymaker approved both a subordinate’s decision and the improper basis for that decision. The municipality’s conduct must also have been the moving force behind the constitutional violation.

The court held that the allegations that Essick adopted the investigation’s findings, knew about the deputies’ conduct, and approved their alleged constitutional violations were sufficient to plead that the County ratified the conduct. The court did not decide whether after-the-fact approval must occur before an alleged constitutional violation ends. It held that, regardless, the allegations were sufficient either to support a ratification theory or to further support a theory that the County had a pre-existing policy that caused the alleged violations. The court therefore denied the motion to dismiss the County’s ratification claim.

Disposition

The court granted in part and denied in part the defendants’ motion to dismiss the First Amended Complaint. It granted the motion as to dismissing Essick as a defendant and denied the motion as to the remainder.