Mattingly v. California Department of Parks and Recreation

Background

Michael Joseph Mattingly sued the California Department of Parks and Recreation (CDPR) and several individual officers. According to the complaint, Mattingly participated in a small protest at Twin Lakes Beach on July 31, 2021. He alleged that officers surrounded the protesters, forced him backward, assaulted him, knocked items from his hands, handcuffed him, and detained him. He also alleged that the officers targeted protesters to suppress their speech. The complaint stated that all charges from the state-court proceedings were dismissed on November 30, 2022.

Mattingly asserted claims under 42 U.S.C. § 1983, a federal civil-rights law, based on the Fourth, Fifth, and First Amendments. He also asserted claims under the California Constitution and a California Government Claim. The individual officer defendants answered the complaint. CDPR moved under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) to dismiss Mattingly’s federal claims against CDPR.

Arguments and Analysis

CDPR argued that the Eleventh Amendment barred Mattingly’s federal claims and that CDPR was not a “person” that could be sued under § 1983. The Eleventh Amendment generally protects states and state agencies from private lawsuits in federal court, subject to recognized exceptions.

The court determined that CDPR is a California state agency responsible for administering the state parks. It concluded that California had not waived its Eleventh Amendment protection for § 1983 claims, that Congress had not removed that protection through § 1983, and that the exception allowing certain prospective injunctions against state officials did not apply to a state agency such as CDPR. The court also concluded that a state or an entity considered an arm of the state is not a “person” under § 1983.

Disposition

The court granted CDPR’s motion to dismiss Mattingly’s federal claims. It dismissed all of Mattingly’s federal claims against CDPR without leave to amend because, on the record before it, no additional facts could make those claims viable against CDPR. The order does not state a disposition for the claims against the individual officers or for Mattingly’s state-law claims.