Black Lives Matter Seattle-King County v. City of Seattle

CourtDistrict Court, W.D. Washington
DecidedJanuary 28, 2021
Docket2:20-cv-00887
StatusUnknown

This text of Black Lives Matter Seattle-King County v. City of Seattle (Black Lives Matter Seattle-King County v. City of Seattle) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Black Lives Matter Seattle-King County v. City of Seattle, (W.D. Wash. 2021).

Opinion

1 HONORABLE RICHARD A. JONES

8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE

10 BLACK LIVES MATTER SEATTLE-KING 11 COUNTY, ABIE EKENEZAR, SHARON SAKAMOTO, MURACO KYASHNA- Case No. 2:20-cv-00887-RAJ 12 TOCHA, ALEXANDER WOLDEAB, NATHALIE GRAHAM, AND ORDER ON MOTIONS FOR 13 ALEXANDRA CHEN, CONTEMPT SANCTIONS (Dkt. # 164), ATTORNEYS’ FEES (Dkt. 14 # 166), AND RECONSIDERATION Plaintiffs, AND LEAVE TO SUPPLEMENT 15 THE RECORD (DKT. # 178) v.

16 CITY OF SEATTLE, SEATTLE POLICE 17 DEPARTMENT, 18 Defendant. 19 I. INTRODUCTION 20 Before the Court are three motions. Having considered the submissions of the 21 parties, the relevant portions of the record, and the applicable law, the Court finds that 22 oral argument is unnecessary. For the reasons below, Plaintiffs’ Motion for Contempt 23 Sanctions (Dkt. # 164) is GRANTED in part and DENIED in part; Plaintiffs’ Petition 24 for Attorneys’ Fees (Dkt. # 166) is GRANTED in part and DENIED in part; and 25 Defendant’s Motion for Reconsideration and Request for Leave to Supplement the 26 Record (Dkt. # 178) is DENIED. 27 1 II. BACKGROUND 2 On December 7, 2020, the Court found Defendant City of Seattle (“City”) in 3 contempt for violating the Court’s preliminary injunction orders. Dkt. # 161. That ruling 4 was the result of a contempt proceeding set in motion months earlier. 5 In late September, Plaintiffs filed a motion for an order to show cause why the 6 City should not be held in contempt for violating the Court’s preliminary injunction 7 orders. Dkt. # 114. It was the second time Plaintiffs sought to hold the City in contempt. 8 Two months before, Plaintiffs had filed another contempt motion. Dkt. # 51. That 9 motion was initially set for an evidentiary hearing, Dkt. ## 89, 90, until the parties 10 stipulated to dismiss the motion without prejudice and to enter an amended preliminary 11 injunction, Dkt. # 110. 12 In their second motion for contempt, Plaintiffs claimed that the City violated the 13 original preliminary injunction order, Dkt. # 42, and the amended preliminary injunction 14 order, Dkt. # 110, during several protests. Specifically, Plaintiffs contended that the 15 City’s use of crowd control weapons on August 26, September 7, September 22, and 16 September 23 of last year violated the two orders. Dkt. # 114. 17 Like the previous motion for contempt, the Court held a status conference to 18 determine how to proceed with an evidentiary hearing. Dkt. ## 140, 159. The Court also 19 asked whether the parties would stipulate to an alternative process. Id. Days after the 20 conference, the parties agreed that the Court could consider the motion for contempt 21 “based entirely on [] written submissions and without any live testimony.” Dkt. # 141 at 22 2; see also Dkt. ## 142, 143. And so the Court did. In addition to its initial response to 23 Plaintiffs’ contempt motion, the City filed a supplemental response. Dkt. # 144. The 24 supplemental response was supported by several declarations, containing scores of video 25 evidence and police officer “use of force reports. Dkt. ## 145-151. In turn, Plaintiffs 26 filed their reply. Dkt. # 152. On November 18, 2020, the Court heard oral argument on 27 the motion. Dkt. # 160. 1 Weeks later, after reviewing both parties’ submissions and hearing oral argument, 2 the Court granted in part and denied in part Plaintiffs’ contempt motion and held the City 3 in contempt. Dkt. # 161. The contempt order identified four violations of the 4 preliminary injunction orders and four “compliant uses.” The remaining deployments, 5 the Court held, were neither violations nor compliant uses. To determine the appropriate 6 sanction, the Court requested supplemental briefing. 7 Since then, the parties have filed three motions. Dkt. ## 164, 166, 178. As 8 requested, Plaintiffs filed a motion for contempt sanctions, in which they explain their 9 requested sanctions. Dkt. # 164. Part of their request is a request for attorneys’ fees, so 10 they also filed a separate petition to that end. Dkt. # 166. The City responded to both 11 motions, Dkt. ## 171, 176, and filed a motion of its own, a motion for reconsideration 12 and leave to supplement the record, Dkt. # 178. Those motions are now before this 13 Court, and the Court addresses each in turn. 14 III. DISCUSSION 15 A. Motion for Reconsideration and Leave to Supplement the Record (Dkt. 16 # 178) 17 Found in contempt of the Court’s preliminary injunction orders, the City now asks 18 for reconsideration. Dkt. # 178. According to the City, the Court erred “because it did 19 not apply the Monell standard; erroneously held the City to a perfect, rather than 20 substantial, compliance standard; and incorrectly concluded 4 of 122 deployments 21 violated the injunction[s].” Id. at 3. The Court finds no such error. 22 i. Standing Order – Meet and Confer 23 Under this Court’s standing order, “counsel contemplating the filing of any motion 24 shall first contact opposing counsel to discuss.” Dkt. # 24 ¶ 6 (emphasis in original). 25 This is a strict requirement. Id. Before filing this motion, the City did not meet and 26 confer with Plaintiffs, nor did it seek to meet and confer. Dkt. # 187 ¶ 3. This is a 27 violation of the Court’s standing order. Though the Court will not strike the motion on 1 that basis, it will not hesitate to do so in the future. 2 ii. Legal Standard 3 Motions for reconsideration are disfavored under the Local Rules for the Western 4 District of Washington. Local Rules W.D. Wash. LCR 7(h)(1). “[I]n the absence of a 5 showing of manifest error in the prior ruling or a showing of new facts or legal authority 6 which could not have been brought to [the Court’s] attention earlier with reasonable 7 diligence,” such motions will ordinarily be denied. Id. “A motion for reconsideration 8 ‘may not be used to raise arguments or present evidence for the first time when they 9 could reasonably have been raised earlier in the litigation.’” Marlyn Nutraceuticals, Inc. 10 v. Mucos Pharma GmbH & Co., 571 F.3d 873, 880 (9th Cir. 2009) (emphasis in original) 11 (quoting Kona Enters., Inc. v. Estate of Bishop, 229 F.3d 877, 890 (9th Cir. 2000)). 12 iii. Monell 13 The City previously argued that, to find it in contempt, the Court must fuse the 14 civil contempt standard with the municipal liability standard articulated in Monell v. 15 N.Y.C. Dep’t of Soc. Servs., 436 U.S. 658, 692 (1978). Dkt. # 144 at 4-5. The Court 16 already considered the argument and rejected it. Dkt. # 161 at 9-10. The City insists that 17 this was in error. Dkt. # 178 at 3-5. But it is the City that is mistaken. 18 The City claims that although individual SPD officers are indeed bound by the 19 preliminary injunction orders, the “legal question of which entities and individuals are 20 bound . . . is distinct from the legal question of what constitutes a violation by the City as 21 a whole.” Dkt. # 178 at 3. The Court’s contempt finding, it says, still needed to be based 22 on an “unconstitutional policy or practice.” Id. Despite having multiple opportunities to 23 do so, the City has cited no case in which a court has fused the civil contempt analysis 24 and the municipal liability analysis in this way. 25 In re-raising this argument, the City does not raise new facts or intervening law 26 that were not previously available to it. The Court presumes then that the City is seeking 27 reconsideration for manifest error. 1 The Court rejects the City’s call to ignore the well-settled standard for civil 2 contempt in favor of a makeshift legal standard that the City just fashioned. The City’s 3 proposed standard fails for many reasons, two chief among them.

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Black Lives Matter Seattle-King County v. City of Seattle, Counsel Stack Legal Research, https://law.counselstack.com/opinion/black-lives-matter-seattle-king-county-v-city-of-seattle-wawd-2021.