Wilson v. City Of Oakland

Background

Matthew Wilson and Joshua Barnes alleged that, while they were driving on December 5, 2019, California Highway Patrol officials and a City of Oakland police officer stopped them. They alleged that they were then subjected to excessive force and unlawful detention. The complaint asserted claims under 42 U.S.C. § 1983, the federal civil-rights statute used for certain constitutional claims against government actors, as well as claims under state law.

Motion and parties’ positions

The California Highway Patrol moved to dismiss the claims against it. It argued that the Eleventh Amendment barred a federal lawsuit against a state or one of its agencies or departments without the state’s consent, regardless of the relief sought. The plaintiffs did not dispute that general legal principle. Instead, they argued that the motion was irrelevant and moot because they had not brought a claim directly against the California Highway Patrol.

Court’s ruling

The court rejected the plaintiffs’ characterization of the complaint. It noted that they named the California Highway Patrol as a defendant in the caption, served it with a summons identifying it as a defendant, and asserted their claims against the defendants without distinguishing among them. The court therefore concluded that the plaintiffs had brought claims against the patrol and that those claims were barred by the Eleventh Amendment. The court granted the California Highway Patrol’s motion to dismiss.

The court vacated the scheduled hearing. A footnote stated that the California Highway Patrol did not seek dismissal of the claims against the unnamed California Highway Patrol officers, and the court did not further address those claims. The opinion does not state that the dismissal was with or without prejudice.