Reeves v. Alvarado

Background

Reeves alleged that, on December 21, 2022, three or four Alameda County deputy sheriffs detained her at the Oakland airport before a flight, said there was an arrest warrant, handcuffed her, and sexually assaulted her with an object. She also mentioned a strip search during booking. Reeves further alleged that, when she reported the incident to a state-court judge a day or two later, the judge held her in contempt and sentenced her to 30 days in jail.

The opinion says Reeves sued the Alameda County Sheriff, asserting an unreasonable search and seizure. The defendant moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The motion argued that the complaint did not allege facts about the Sheriff’s personal participation and did not support liability based on a County policy or custom.

Court’s analysis

The court held that Reeves alleged no personal participation by the Sheriff and did not plead facts supporting municipal liability under Monell. Under that doctrine, a local government may be liable under 42 U.S.C. § 1983 when an official policy or custom causes a constitutional violation, but it cannot be held responsible merely because its employees allegedly committed wrongful acts. The court found no factual allegations supporting such a policy-or-custom claim.

To the extent Reeves challenged the state-court judge’s contempt decision, the court said the judge had absolute immunity for decisions made as part of judicial functions. The court also said the federal court lacked subject-matter jurisdiction under the Rooker-Feldman doctrine to hear a direct or equivalent appeal from that state-court judgment. The opinion therefore treated the claim against the judge as barred from federal review.

The court separately discussed possible claims against the arresting deputies, although Reeves had not named them. It said that, if the alleged conduct occurred, the allegations could plausibly state claims against the individual deputies for wrongful arrest, excessive force, or unlawful seizure, depending on the facts. The court explained that Reeves could identify the deputies as defendants or use Doe designations if their names were unknown.

The court also discussed a possible strip-search claim. It said Reeves had not asserted an unreasonable-strip-search claim as a standalone claim and that the allegations in the attachment likely would not state such a claim if she intended to bring one.

Finally, the court noted that Reeves did not oppose the motion to dismiss. Although failure to oppose can support dismissal, the court observed that she was attempting to prosecute the case, including by seeking subpoenas for video and audio evidence and filing an alternative-dispute-resolution certification.

Disposition

Judge Beeler granted the motion to dismiss with leave to amend. The court directed Reeves to file an amended complaint by April 19, 2024, and stated that the order disposed of ECF No. 9. The court did not enter a merits judgment on the alleged conduct.