Taylor v. San Francisco Sheriff's Department

Background

Mechiel Taylor represented herself in an action against sixteen defendants. The first amended complaint asserted seven claims: First Amendment free-speech, Fourth Amendment search-and-seizure, and Fourteenth Amendment equal-protection claims under 42 U.S.C. § 1983; hostile-work-environment claims under Title VII and Title IX; trespass to chattel; and invasion of privacy by intrusion upon seclusion. Taylor sought compensatory and punitive damages and injunctive relief.

Taylor alleged that Five Keys Schools and Programs hired her as a teacher at Santa Rita Jail in 2016. She alleged that Nicole Tremaine Allen, an Alameda County Sheriff’s Office deputy who had worked in the same jail’s inmate-services area, searched or seized Taylor and her property, violated a temporary restraining order at the workplace, and later appeared at Taylor’s home. Taylor also alleged that Five Keys, the United Educators of San Francisco, law-enforcement agencies, government entities, and individual officials failed to respond appropriately to her complaints, denied benefits or workplace protections, or discriminated against her. The City of San Ramon was voluntarily dismissed before this order, and five Five Keys defendants had answered rather than moved to dismiss.

Rulings on the Motions

The court treated the motions as challenges under Rules 8(a), 12(b)(1), and 12(b)(6). Rule 12(b)(1) concerns subject-matter jurisdiction, while Rule 12(b)(6) tests whether the complaint states a legally sufficient claim. The court applied the rule that self-represented pleadings are read liberally, but that this does not allow the court to supply missing elements of a claim.

Superior Court of California, Contra Costa County

The court granted the Superior Court’s motion to dismiss without leave to amend. It held that the Superior Court, as an arm of the State of California, was immune from Taylor’s § 1983 claim. Taylor conceded that the Superior Court was not her employer, so the Title VII claim was dismissed with prejudice. The Title IX claim was also dismissed with prejudice because Taylor could not allege that the discrimination occurred in an educational program operated by the Superior Court.

The court additionally held that all three claims were barred by the Rooker-Feldman doctrine, which prevents a federal district court from acting as an appeal court reviewing a state-court decision. The court found that Taylor’s claims attacked the reasoning behind Judge Judith Craddick’s denial of a permanent restraining order and sought relief that would effectively reverse that decision.

United Educators of San Francisco and Matthew Milton

The court granted the UESF Defendants’ motion to dismiss without leave to amend. It held that UESF and Milton were private actors, not state actors, and therefore Taylor could not bring a § 1983 claim against them. Taylor did not allege facts supporting any recognized basis for treating their conduct as state action, such as joint action with the government or government coercion.

The Title IX claim was dismissed with prejudice because Taylor conceded that her complaint did not concern an educational program or activity operated by UESF. The Title VII claim was also dismissed with prejudice. Although a union can be liable under Title VII in some circumstances, Taylor did not allege that UESF treated her less favorably because of race or gender or retaliated against her for asserting Title VII rights. The court dismissed all claims against UESF and Milton with prejudice.

City and County of San Francisco and San Francisco Sheriff’s Department

The court granted the San Francisco Defendants’ motion to dismiss. It dismissed the San Francisco Sheriff’s Department as a party because Taylor did not allege that it was a separate legal entity from the City and County of San Francisco, which was already named as a defendant. The claims against the Sheriff’s Department were dismissed with prejudice.

The court dismissed Taylor’s § 1983 claims against the City and County of San Francisco with prejudice. Taylor did not allege facts showing that a San Francisco policy or custom, failure to train, or final policymaker’s decision caused a constitutional violation. Taylor’s invasion-of-privacy claim against the San Francisco Defendants was dropped in her opposition.

The court dismissed Taylor’s Title VII and Title IX claims against the City and County of San Francisco but allowed her to amend them. Taylor had not adequately alleged that the City and County was her employer. She also had not alleged sufficient facts supporting a hostile work environment, ratification or acquiescence in harassment for Title VII purposes, or substantial control, actual knowledge, and deliberate indifference for Title IX purposes. The court allowed amendment only to those Title VII and Title IX claims against the City and County.

State of California

The court granted California’s motion to dismiss without leave to amend. Taylor’s § 1983 claim was dismissed with prejudice because § 1983 claims could not be brought against the State. Her Title VII claim was dismissed with prejudice because California was not alleged to be her employer. Her Title IX claim was dismissed with prejudice because the allegations did not concern an educational program or activity operated by California.

County of Alameda, Alameda County Sheriff’s Office, and Nicole Tremaine Allen

The court granted the Alameda Defendants’ motion to dismiss. It dismissed the Alameda County Sheriff’s Office as a party under Rule 21 because the County of Alameda was already named and the complaint did not establish that the Sheriff’s Office was a separate suable entity.

The court dismissed Taylor’s § 1983 claims against Allen but allowed amendment. Taylor had not pleaded enough facts to show whether Allen acted under color of state law or as a private individual, and she had not alleged specific facts establishing violations of the First, Fourth, or Fourteenth Amendments. Taylor may amend those claims to describe what Allen allegedly did and how Allen was acting under color of law.

The court dismissed Taylor’s § 1983 claim against the County of Alameda with leave to amend because the complaint did not allege that a County policy or custom caused a constitutional injury.

Taylor’s Title VII and Title IX claims against Allen were dismissed with prejudice because those statutes do not permit claims against individuals. Taylor’s Title VII claim against the County of Alameda was dismissed with leave to amend. She had not adequately alleged that the County was her joint employer, exhausted administrative remedies, or subjected her to a hostile work environment based on a protected characteristic. Her Title IX claim against the County was also dismissed with leave to amend because she had not adequately alleged sex-based harassment, substantial control over Allen and the setting, or deliberate indifference.

The court dismissed Taylor’s trespass-to-chattel claim against Allen because she alleged only conclusory unauthorized contact with her property and did not allege damage or interference with its use. The court allowed amendment of that claim. The court also dismissed Taylor’s intrusion-upon-seclusion claim against Allen with leave to amend because she did not allege enough facts showing a reasonable expectation of privacy or an intrusion highly offensive to a reasonable person.

The court dismissed Taylor’s state-law claims against the County of Alameda with leave to amend. Taylor had not alleged that Allen’s conduct occurred within the scope of her employment or benefited the County.

Gregory Ahern and Daniel Brodie

The court granted Ahern and Brodie’s motion to dismiss. Taylor’s Title VII and Title IX claims against them were dismissed without leave to amend because those statutes do not permit claims against individuals.

The court dismissed Taylor’s § 1983 claims against Ahern and Brodie with leave to amend. Taylor had not adequately alleged that Allen herself violated § 1983, that Ahern and Brodie supervised Allen, or that they knew of constitutional violations and failed to prevent them. The court allowed amendment only as to the § 1983 claims against Ahern and Brodie.

Disposition

The court ordered Taylor to file an amended complaint by June 21, 2024. The motions to dismiss were granted as follows: the Superior Court’s and UESF Defendants’ motions were granted without leave to amend; the San Francisco Defendants’ motion was granted, with amendment limited to Title VII and Title IX claims against the City and County of San Francisco; California’s motion was granted without leave to amend; the Alameda Defendants’ motion was granted, with amendment permitted for all claims against the County of Alameda and for § 1983 and state-law claims against Allen; and Ahern and Brodie’s motion was granted, with amendment permitted only for their § 1983 claims.