Langham v. Granzella

Background

Malik Langham alleged that Officers Antonio Granzella and DeWald stopped him on November 15, 2022. According to the operative complaint, Granzella asked whether Langham had a California driver’s license, and Langham said that he had a valid Florida license. The officers searched his clothing, told him that his vehicle would be towed because he was unlicensed, cited him for driving without a license and speeding, arrested him, searched his car without a warrant or his consent, and had the vehicle towed.

Langham was later convicted in traffic court of driving without a valid license and exceeding the speed limit. He asserted a Fourth Amendment claim under 42 U.S.C. § 1983, the federal civil-rights statute used for certain claims against state or local officials, along with related state-law claims.

Judicial Notice

The defendants asked the court to recognize several facts from documents concerning Langham’s traffic citation and convictions, as well as a declaration stating that he had not filed a government tort claim concerning the incident. The court granted in part the request as to the two documents concerning the state traffic proceeding because that proceeding was directly related to the court’s analysis. The court denied as moot the request concerning the third document because it did not consider that document in deciding the motion.

Federal Civil-Rights Claim

The defendants argued that the federal claim was barred by the rule from Heck v. Humphrey. That rule prevents a person from recovering damages under § 1983 when success would necessarily undermine an existing conviction, unless the conviction has already been reversed, invalidated, expunged, or otherwise called into question through one of the methods identified by the Supreme Court.

The court agreed. It reasoned that Langham’s allegations challenged whether he was driving without a valid license and challenged the lawfulness of the search and seizure of his vehicle and person. In the court’s view, success on those allegations would necessarily imply that his traffic convictions were invalid. The court therefore granted the motion to dismiss the § 1983 claim based on Heck.

The court expressly stated that it did not reach the merits of that claim. It explained that the claim, as currently pleaded, was not cognizable unless and until the traffic conviction was reversed, expunged, declared invalid, or called into question by a federal court’s issuance of a writ addressing the conviction. The court gave Langham leave to amend, but stated that any amended complaint could not be based on the theory that the defendants lacked probable cause to search and seize his vehicle or arrest him.

State-Law Claims

The remaining claims alleged violations of state law. The court explained that California’s Government Claims Act generally requires claims for money or damages against local public entities to be presented before suit is filed. It also requires a complaint to allege facts showing compliance with that requirement or explaining why compliance was excused.

The court did not decide whether Langham had timely presented a claim. Instead, it dismissed the state-law claims because the operative complaint did not allege compliance with, or an excuse from, the Government Claims Act. The court granted the defendants’ motion on that ground and permitted Langham to amend to allege sufficient facts establishing compliance or excusal. The court stated that if no such facts existed, Langham could not assert state-law tort claims against the defendants.

Disposition

The court granted the defendants’ motion to dismiss with leave to amend. Langham was directed to file an amended complaint within 21 days of the order, if he could state claims that met federal pleading requirements, were not barred by Heck, and alleged compliance with or excusal from the Government Claims Act.