Delacruz v. Tanimura & Antle, Inc.

Background

Daniel Delacruz, who represented himself, sued Tanimura & Antle, Inc. (TAI), Mike Antle, Carmen Ponce, and Claudia Quirarte. The order addressed the motion to dismiss filed by TAI, Antle, and Ponce, referred to collectively as the TAI defendants. The court stated that Quirarte’s motion to dismiss would be addressed in a separate order.

Delacruz alleged that he has Fabry Disease and receives regular enzyme replacement therapy. He claimed that, beginning around 2019, the TAI defendants interfered with his medical treatment by spreading a claim that he was not disabled and causing Quirarte to mistreat him during medical appointments. His complaint also described events and legal proceedings dating back several decades, including his former employment with TAI, an earlier state-court lawsuit and settlement, bankruptcy proceedings, and an earlier federal lawsuit.

The complaint asserted six claims: disability discrimination and retaliation under the Americans with Disabilities Act; civil-rights violations under 42 U.S.C. § 1983; two claims under 42 U.S.C. § 1981; disability-discrimination claims under California law; and a claim under the California Constitution. The TAI defendants moved to dismiss under Federal Rules of Civil Procedure 8 and 12(b)(6), arguing that the complaint was too unclear and failed to state plausible claims. They also primarily argued that claim preclusion, sometimes called res judicata, barred the claims because of earlier litigation.

Motion to Strike

Delacruz moved to strike the TAI defendants’ reply brief as late. The court agreed that the reply was filed more than two weeks after the deadline and that the defendants had not shown good cause for the delay. But Delacruz did not claim that the late filing prejudiced him, and he used his motion to submit unauthorized additional arguments. The court therefore denied the motion to strike, considered the late reply and Delacruz’s unauthorized additional arguments, and warned both sides to follow applicable filing rules.

Pleading Requirements

The court held that the complaint violated Rule 8 because it contained sweeping, prolix allegations about many events over several decades without clearly distinguishing facts supporting the asserted claims from background information. The allegations did not provide fair notice of the grounds for the claims against the TAI defendants.

The court also applied Rule 12(b)(6), which permits dismissal when a complaint does not state enough facts to support a legally recognized claim. Even construing Delacruz’s self-represented pleading liberally, the court concluded that the complaint did not allege facts supporting plausible relief.

Claim Preclusion

The TAI defendants argued that claim preclusion barred the claims. The court took judicial notice of specified documents from Delacruz’s earlier federal action, including pleadings, dismissal orders, a judgment, appellate orders, and the United States Supreme Court’s denial of review. Judicial notice allowed the court to recognize the existence and contents of appropriate public records, but not disputed facts contained in those records.

The court said it was not clear on the briefing whether claim preclusion applied because the earlier federal action had been dismissed, at least in part, on jurisdictional grounds. The complaint also involved Quirarte, who was not a party to the earlier action, and included some later events that the TAI defendants had not shown could have been litigated earlier. The court therefore did not need to resolve the claim-preclusion issue because the complaint independently failed under Rules 8 and 12(b)(6).

Americans with Disabilities Act Claims

The court concluded that the complaint did not state a plausible disability-discrimination or retaliation claim under the employment and retaliation provisions of the Americans with Disabilities Act. The complaint did not identify clearly which ADA provisions or titles applied. The alleged conduct concerned interference with medical treatment beginning around 2019, while Delacruz’s employment with TAI had ended nearly thirty years earlier. The court also found conclusory the allegation that Quirarte acted as the TAI defendants’ agent.

The court dismissed the ADA claim against the TAI defendants without leave to amend, meaning the court did not allow amendment of that claim in this action. It stated that amendment would be futile because the employment relationship had ended many years before the alleged conduct.

Civil-Rights Claim Under Section 1983

A claim under 42 U.S.C. § 1983 requires a violation of a federal right by a person acting under color of state law. The TAI defendants argued that the complaint did not allege that they were state actors. Delacruz responded that they acted under color of state law through alleged cooperation with the California State Bar involving evidence tampering and falsehoods.

The court found those allegations conclusory. It also found no facts plausibly showing that the private TAI defendants could be treated as state actors or establishing a plausible connection between the California State Bar and the alleged interference with Delacruz’s medical treatment in 2019. The court granted the motion to dismiss the § 1983 claim and dismissed it without leave to amend.

Claims Under Section 1981

The court explained that 42 U.S.C. § 1981 prohibits race-based discrimination in making and enforcing contracts. Although Delacruz stated that he is Latino, the complaint did not allege facts suggesting that the TAI defendants acted because of his race. Instead, the allegations attributed the defendants’ conduct to their alleged belief that he was not disabled and to ill will related to his 2019 comment about Rick Antle’s death.

The court granted the motion to dismiss Delacruz’s two § 1981 claims. It dismissed those claims without leave to amend because the record did not show that additional allegations could cure the pleading defects.

State-Law Claims and Disposition

After dismissing all of the federal claims without leave to amend, the court declined to exercise supplemental jurisdiction over the remaining state-law claims. It dismissed those claims without prejudice, meaning the order did not bar refiling them on that basis.

In conclusion, the court granted the TAI defendants’ motion to dismiss Delacruz’s federal claims under Rules 8 and 12(b)(6) without leave to amend. It declined supplemental jurisdiction over the remaining state-law claims and dismissed those claims without prejudice. The order did not decide Quirarte’s separate motion to dismiss.