Williams v. City of Pleasanton

Background

Williams’s case arose from her arrest on November 14, 2019, at ValleyCare, a hospital in Pleasanton, California, while her husband was receiving treatment. After an earlier order dismissed several claims but allowed amendment, Williams filed a First Amended Complaint. The ValleyCare defendants again moved to dismiss her battery, Ralph Act, Bane Act, and malicious prosecution claims.

Battery

Williams alleged that Arianna Welch Frangieh intentionally and violently shoved her through a hospital curtain after Williams asked that Frangieh not enter the room. The defendants argued that Williams had not adequately alleged the required intent to harm or offend or any resulting harm. The court rejected that argument, finding that intent and harm could reasonably be inferred from the allegation that Frangieh intentionally and violently shoved Williams. The court therefore denied the motion to dismiss the battery claim against Frangieh.

Williams also sued hospital entities under respondeat superior, a theory that can make an organization responsible for an employee’s conduct. The defendants argued that SHC and ValleyCare Foundation did not operate the hospital or employ Frangieh. Based on documents subject to judicial notice, the court accepted that argument and dismissed the battery claim without prejudice against SHC and ValleyCare Foundation. The court denied the motion to dismiss the battery claim against ValleyCare.

Ralph Act and Bane Act

The Ralph Act prohibits violence or intimidation by threat of violence based on protected characteristics. The Bane Act prohibits interference, or attempted interference, with rights under federal or California law through threats, intimidation, or coercion. Williams alleged that ValleyCare defendants treated her and her husband discriminatorily because she is Black, called the police, and falsely described her as dangerous, leading to her arrest and alleged police violence.

The court concluded that the complaint did not adequately allege that the ValleyCare defendants themselves committed violence or threats of violence against Williams, other than the separately pleaded shove by Frangieh. The complaint also did not identify which defendants allegedly lied to police or provide facts beyond speculation. The court further found that the hospital defendants did not control how police responded to the call or how the arrest unfolded, and Williams cited no authority extending Ralph Act or Bane Act liability to these circumstances. The Ralph Act and Bane Act claims were dismissed with prejudice.

Malicious Prosecution

Malicious prosecution is a claim that a defendant improperly helped start or pursue a criminal case without probable cause and with malice. Williams alleged that Frangieh, Girard, Ramsey, Nitro, and Estrada gave false information to police and later communicated with prosecutors to encourage criminal charges.

The court found that Williams did not identify the allegedly false information each ValleyCare defendant provided to the District Attorney concerning the battery charge against Williams. The complaint contained only a general assertion that the defendants sent communications and made calls encouraging prosecution. Because Williams had not previously been directed specifically to identify that information and the person who provided it, the court dismissed the malicious prosecution claim with leave to amend within 20 days.

Disposition

Judge William H. Orrick’s order states that the motion to dismiss the battery claim was granted in part as to SHC and ValleyCare Foundation and denied as to Frangieh and ValleyCare. The Ralph Act and Bane Act claims were dismissed with prejudice. The malicious prosecution claim was dismissed with leave to amend within 20 days.