Bratt v. Carlsbad Police Department

CourtDistrict Court, S.D. California
DecidedJune 25, 2025
Docket3:24-cv-01295
StatusUnknown

This text of Bratt v. Carlsbad Police Department (Bratt v. Carlsbad Police Department) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bratt v. Carlsbad Police Department, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BRYAN BRATT, Case No.: 24-CV-1295 JLS (BLM)

12 Plaintiff, ORDER GRANTING IN PART AND 13 v. DENYING IN PART AS MOOT DEFENDANT CITY OF 14 CARLSBAD POLICE DEPARTMENT, CARLSBAD’S MOTION TO CARLSBAD COMMUNITY THEATRE, 15 DISMISS AND DEFENDANT and DOES 1-100, PATRONS OF THE ARTS 16 Defendants. FOUNDATION DBA CARLSBAD 17 COMMUNITY THEATER’S MOTION TO DISMISS 18

19 (ECF Nos. 10, 11)

21 Presently before the Court are Defendant City of Carlsbad’s (the “City”) Motion to 22 Dismiss Plaintiff’s First Amended Complaint (“City Mot.,” ECF No. 10), the City’s 23 Memorandum of Points and Authorities in support thereof (“City Mem.,” ECF No. 10-1), 24 and Defendant Patrons of the Arts Foundation dba Carlsbad Community Theater’s 25 (“CCT”) Motion to Dismiss (“CCT Mot.,” ECF No. 11). Plaintiff Bryan Bratt (“Plaintiff”) 26 filed a single Opposition, purportedly to both Motions (“Opp’n,” ECF No. 13), to which 27 only the City filed a Reply (“City Reply,” ECF No. 16). The Court took both Motions 28 under submission without oral argument pursuant to Civil Local Rule 7.1(d)(1). See ECF 1 No. 15. 2 Having carefully considered Plaintiff’s First Amended Complaint (“FAC,” ECF 3 No. 8), the Parties’ arguments, and the law, the Court now GRANTS IN PART AND 4 DENIES IN PART AS MOOT the Motions. 5 BACKGROUND 6 I. Procedural Background 7 Plaintiff, proceeding pro se, initially filed his Complaint in state court on June 17, 8 2024, naming Carlsbad Police Department (“Carlsbad PD”), CCT, and DOES 1–100 as 9 Defendants. See ECF No. 1-3 (“Compl.”). The City subsequently removed the case, 10 asserting federal question jurisdiction based on Plaintiff’s 42 U.S.C. § 1983 claim and 11 supplemental jurisdiction as to his remaining causes of action.1 ECF No. 1 (“Notice of 12 Removal”) at 1–2. Plaintiff’s Complaint alleged that he “planned a peaceful protest” after 13 CCT made a decision that “unfairly cast [Plaintiff] in a negative light.” Compl. ¶ 2. On 14 June 24—just days before the scheduled protest— Carlsbad PD allegedly sent Plaintiff a 15 “cease and desist directive.” Id. ¶ 17. The directive purportedly ordered Plaintiff not to go 16 through with the protest and threatened him with legal consequences. Id. When Plaintiff 17 asked Carlsbad PD about the directive, “the department informed him that they had no 18 record of the incident.” Id. ¶ 18. Paradoxically, however, Carlsbad PD was able to “discuss 19 the specifics of the situation when pressed.” Id. Later, representatives from Carlsbad PD 20 supposedly told Plaintiff that “they typically do not issue cease and desist orders.” Id. ¶ 21. 21 Plaintiff was never afforded a hearing to contest the basis of the directive. Id. ¶ 20. Plaintiff 22 alleges the foregoing events led to his “social and professional ostracism,” thereby harming 23 him emotionally and economically. See id. ¶ 22. Plaintiff sought, among other things, a 24 declaratory judgment, compensatory and punitive damages, and a permanent injunction 25 prohibiting Defendants from violating Plaintiff’s constitutional rights further. See id. 26 27 28 1 The City claims Plaintiff erroneously sued Carlsbad PD and should have named the City. City Mem. 1 at Prayers/Submissions. 2 The City then filed a Motion to Dismiss, see ECF No. 2, which the Court granted on 3 August 19, 2024, see ECF No. 6 (“Order”). Specifically, the Court found Plaintiff’s state 4 law claims were subject to dismissal as Plaintiff failed to plead compliance with the 5 presentment and timing requirements of the California Government Claims Act. Order 6 at 4–6. Next, the Court found Plaintiff’s § 1983 claim was subject to dismissal as it was 7 untimely, and Plaintiff had failed to sufficiently plead municipal liability. Id. at 6–10. 8 However, in light of Plaintiff’s pro se status, the Court granted him an opportunity to 9 amend his Complaint. Id. at 10–11. 10 CCT then filed a Motion to Dismiss Plaintiff’s Complaint. ECF No. 7. Plaintiff 11 filed his FAC thereafter. See FAC. Consequently, the Court denied CCT’s Motion as moot 12 in light of the newly amended complaint. See ECF No. 9. The City and CCT then each 13 filed the instant Motions to Dismiss Plaintiff’s FAC. See City Mot.; see also CCT Mot. 14 II. Factual Allegations in the FAC 15 Plaintiff’s FAC alleges that on or about June 2019, he engaged “in peaceful 16 organizational activities aimed at protesting decisions made by [CCT], which he believed 17 to be discriminatory and exclusionary.” FAC ¶ 15. He purportedly planned a “peaceful 18 protest near the premises of CCT[,]” id. ¶ 15, then, on or about July 30, 2019, received a 19 phone call “from an individual claiming to be an officer of Defendant Carlsbad [PD],” 20 informing him that “he must cease and desist his protest activities immediately or face legal 21 action,” id. ¶ 16. This caused him to cancel the planned protest, id., yet when he later 22 contacted Carlsbad PD and inquired about the “cease and desist directive” (“Directive”), 23 he was informed “the department had no record of such a directive being issued.” Id. ¶ 17. 24 Despite such representation, Carlsbad PD officials, “when pressed, discussed specifics of 25 the situation which contradicted their earlier statements about the absence of such a 26 directive.” Id. ¶ 18. Plaintiff alleges the foregoing events led to his ostracization within 27 his professional and social communities, “resulting in a loss of employment at both Uber 28 and SeaWorld, where employers cited concerns over legal troubles and Plaintiff’s safety in 1 continuing employment (more or less).” Id. ¶ 19. 2 Plaintiff alleges he was “reminded indirectly through third parties associated with 3 CCT and direct communications from Carlsbad PD to refrain from discussing the incident 4 or attending events, perpetuating the initial misinformation and causing ongoing emotional 5 and social harm to Plaintiff.” Id. ¶ 20. Plaintiff then “discovered inconsistencies in 6 Carlsbad PD’s statements which led him to believe that the directive was not only 7 improperly issued but was also part of a broader effort by CCT and Carlsbad to silence and 8 penalize him without due cause.” Id. ¶ 21. And in May 2025, he “uncovered evidence 9 strongly suggesting that the cease and desist order purportedly issued by [Defendant 10 Carlsbad PD] was a fabrication.” Id. ¶ 22. Plaintiff further alleges his “realization and 11 response to the fraudulent nature of the order” was delayed because of the “years of 12 sustained manipulation and suppression” he endured. Id. 13 Next, Plaintiff alleges Defendants “continued to enforce the non-existent cease and 14 desist directive through informal channels.” Id. ¶ 24. He avers that there is a “strong 15 indication that Defendants did not communicate the issuance of the cease and desist 16 directive to the appropriate city authorities.” Id. ¶ 25. And he suggests the Directive is 17 still in place because he was recently “ejected from a show” at Luminary Arts under 18 “dubious pretenses.” Id. ¶ 26. And finally, Plaintiff indicates a “notice of claim was mailed 19 to the city on 8/28/24.” Id. ¶ 15. 20 Plaintiff brings causes of action for: (1) violation of 42 U.S.C. § 1983

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Bratt v. Carlsbad Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bratt-v-carlsbad-police-department-casd-2025.