Matthews v. County of Santa Cruz

Background

Darin Matthews alleged that, on February 19, 2019, a Scotts Valley Police Department vehicle stopped him as he left for work. Officers said the reason was that his vehicle had paper license plates. Matthews alleged that the officers refused to inspect paperwork showing that he had recently purchased the vehicle from an Oregon dealership and that the stated reason for the stop was a pretext for detaining him without probable cause or reasonable suspicion.

The officers ordered Matthews out of the vehicle, held his hands behind his back, and searched him. Deputy Steven Carney ordered him to sit on a police vehicle while officers searched his vehicle, trunk, and backpack. Matthews alleged that he did not consent to those searches. Carney also told him that officers had a warrant for his home. Matthews alleged that Carney made false statements in an affidavit to obtain the warrant and that officers then searched his home.

The first amended complaint asserted five claims: a claim under 42 U.S.C. § 1983 alleging unreasonable searches and seizures; a claim against the County and City for municipal liability; claims under the California Constitution and the Bane Act; assault and battery; and intentional and negligent infliction of emotional distress. The City Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim.

Court’s analysis

The court held that Matthews could proceed against the four named officers even though he could not identify which officer performed each particular action. The allegations said that all four officers were present throughout the stop and suggested that each was involved in the coordinated conduct. The court therefore declined to dismiss the § 1983 claim on the ground that it improperly relied on group liability.

The court also held that Matthews alleged enough facts to state a § 1983 claim based on the vehicle stop. A temporary vehicle stop is a seizure under the Fourth Amendment and generally requires reasonable suspicion of criminal activity. Matthews alleged that nothing about the vehicle, its documentation, or its operation justified the stop and that the paper plates were only a pretext.

The court found the allegations sufficient to support claims concerning the pat-down and the searches of the vehicle and backpack. Because the alleged stop was unlawful and temporary license plates alone did not support a reasonable belief that Matthews was armed and dangerous, the court concluded that the alleged pat-down could violate the Fourth Amendment. Matthews’s allegation that he did not consent to the vehicle and backpack searches also supported the claim.

Matthews did not oppose dismissal of the portion concerning how his home was searched. He also did not address the City Defendants’ arguments concerning unreasonable force and failure to take reasonable steps to protect him. The court treated those arguments as conceded and barred Matthews from pursuing those theories as part of his § 1983 claim.

Disposition

The court dismissed the § 1983 municipal-liability claim against the City without leave to amend because Matthews said he did not wish to preserve it. It also dismissed all of Matthews’s state-law claims without leave to amend because he did not respond to the City Defendants’ arguments for dismissal.

The court’s conclusion states that the motion to dismiss was granted as to all claims except the § 1983 claim. Thus, the motion was granted in part and denied in part, with the § 1983 claim based on the vehicle stop and searches of Matthews’s person, vehicle, and backpack remaining. The City of Scotts Valley and Officers Wayne Belville, Michael Birley, Michael Neronde, and Paul Lopez were ordered to file an answer by February 11, 2022. The order was signed by Judge Edward J. Davila.