Langham v. City of Union City

Background

Malik Langham sued the City of Union City, Justin Noyd, Matthew Mangan, Kyle Scarbrough, Brian Ross, and Brian Baumgartner. The case arose from an October 30, 2022 traffic stop involving Langham’s vehicle. According to the first amended complaint, Officer Kyle Scarbrough initiated the stop and cited Langham for driving without a license. Langham alleged that he had a right to travel freely, that his license was valid and on file, and that the officers needed a warrant for his arrest.

The opinion states that Langham was also cited for having tinted windows. He appeared in traffic court in Fremont, California, on February 21, 2023, and was convicted of both driving without a license and driving with tinted windows. The court granted the defendants’ request for judicial notice of records concerning the citations and convictions.

Rulings

The defendants moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim for relief. The court granted the motion.

Unlawful-seizure claim

The court held that Langham’s Section 1983 unlawful-seizure claim was barred by Heck v. Humphrey. Under that rule, a civil-rights damages claim cannot proceed when success would necessarily imply that an existing conviction is invalid. The court reasoned that challenging the lawfulness of the vehicle seizure would necessarily challenge the validity of Langham’s convictions for driving without a valid license and driving with tinted windows. The court granted the motion to dismiss this claim and dismissed it without leave to amend because no amendment could cure the Heck bar.

California Bane Act claim

Langham also asserted a claim under California Civil Code section 52.1, known as the Bane Act. The court explained that this claim requires specific facts showing that the defendants interfered, or attempted to interfere, with a legal right through threats, intimidation, or coercion. Langham alleged that officers surrounded his car and conducted a search in a threatening and intimidating manner, but he did not explain specifically how the officers threatened, intimidated, or coerced him. The court granted the motion to dismiss the Bane Act claim with leave to amend so that Langham could allege specific supporting facts.

Section 1985 conspiracy claim

Langham alleged that the defendants conspired to violate his rights, including his Fourth Amendment rights, and discriminated against him based on his social class. The court held that a claim under Section 1985(3) requires racial or other qualifying class-based discriminatory animus, and that Langham had not shown that “social class” was a protected class under the authority discussed in the opinion. The court also applied the intra-corporate conspiracy doctrine, which generally treats officers and employees of a single municipality acting within their official duties as legally incapable of conspiring with one another. The court granted the motion to dismiss this claim with prejudice because amendment could not cure the defects.

Section 1986 claim

The court held that a Section 1986 claim depends on a valid Section 1985 claim. Because the Section 1985 claim failed, the Section 1986 claim failed as well. The court granted the motion to dismiss the Section 1986 claim with prejudice because amendment could not cure the defect.

Disposition

The court granted the defendants’ motion to dismiss for failure to state a claim. The unlawful-seizure claim was dismissed without leave to amend; the Bane Act claim was dismissed with leave to amend; and the Section 1985 and Section 1986 claims were dismissed with prejudice. The court stated that Langham could file an amended complaint addressing the Bane Act claim by December 29, 2023. Judge Jeffrey White signed the order on December 4, 2023.