Ramachandran v. City of Los Altos

Background

Satish Ramachandran’s counsel moved to withdraw under the Northern District of California’s Civil Local Rule 11-5. The defendants did not oppose withdrawal but objected to another delay of trial. Ramachandran attended the hearing and agreed that his attorney’s representation should end, although he disagreed with some of the attorney’s descriptions of the circumstances.

The case had been pending for more than three and a half years. The court said that only Ramachandran’s first and fourth claims alleging violations of the First Amendment remained against Ballard, Jordan, and the City of Los Altos. The opinion also describes two earlier attorney withdrawals and prior continuances of the trial date.

Court’s analysis

The court applied Civil Local Rule 11-5 and California professional-conduct rules governing an attorney’s withdrawal. Those rules address circumstances such as an irreparable breakdown in the attorney-client relationship, conduct that makes effective representation unreasonably difficult, and representation that would violate professional obligations. They also require counsel to take reasonable steps to avoid foreseeable prejudice to the client.

The court found that the relationship between Ramachandran and his counsel had broken down beyond repair. It further found that Ramachandran bore significant responsibility for the breakdown and that his conduct had made it unreasonably difficult for counsel to represent him while complying with ethical duties.

Ruling and further proceedings

Judge Demarchi granted plaintiff’s counsel’s motion to withdraw, subject to conditions. Current counsel had to provide Ramachandran with certain forms, templates, and examples for required pretrial materials by December 10, 2021, unless new counsel appeared earlier or Ramachandran declined the materials in writing. If he had not obtained new counsel by December 6, 2021, current counsel had to assist him in registering to use the court’s electronic filing system and continue accepting and forwarding papers. Counsel also had to file a declaration identifying the address where Ramachandran would receive service if he did not obtain new counsel by that date.

The court vacated the December 13, 2021 trial date and the November 29, 2021 pretrial conference. It set an in-person pretrial conference for January 27, 2022, and an in-person trial beginning February 22, 2022. The opinion contains an earlier reference to a February 22, 2021 trial date, but the order’s concluding scheduling provisions identify February 22, 2022.