Broque Anthony Anderson v. San Bernardino Sheriffs Department

CourtDistrict Court, C.D. California
DecidedMay 19, 2023
Docket5:22-cv-01586
StatusUnknown

This text of Broque Anthony Anderson v. San Bernardino Sheriffs Department (Broque Anthony Anderson v. San Bernardino Sheriffs Department) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Broque Anthony Anderson v. San Bernardino Sheriffs Department, (C.D. Cal. 2023).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 5:22-cv-01586-JAK-KES Date: May 19, 2023

Title: BROQUE ANTHONY ANDERSON v. SAN BERNARDINO SHERIFF’S DEPT., et al.

PRESENT:

THE HONORABLE U.S. MAGISTRATE JUDGE KAREN E. SCOTT

Jazmin Dorado Not Present Courtroom Clerk Court Reporter

ATTORNEYS PRESENT FOR ATTORNEYS PRESENT FOR PLAINTIFF: DEFENDANT: None Present None Present

PROCEEDINGS (IN CHAMBERS): Order to Show Cause (“OSC”) Why Complaint Should Not Be Dismissed

In September 2022, the Court received from Plaintiff Broque Anthony Anderson (“Plaintiff”) a 42 U.S.C. § 1983 Complaint against San Bernardino County (“SBC”) and SBC Sheriff Deputies Ramos, Edmond, Olivares, and Alcala (the “Deputy Defendants”). (Dkt. 1.) Plaintiff alleges that on Wednesday, March 17, 2021, he was staying at the Holiday Inn in Loma Linda, California. He had rented a room for about two weeks, paid for in advance. At about 11:30 p.m., he was in the hotel’s computer room. There, the Deputy Defendants arrested Plaintiff for trespassing. (Dkt. 1 at 5.1) Plaintiff was in custody on unrelated matters when he filed this Complaint. (Dkt. 1.) He also filed a request to proceed In Forma Pauperis (“IFP”) which was granted. (Dkt. 2, 12.) Before authorizing service, federal courts must screen inmate and/or IFP complaints and dismiss any case that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief against an immune defendant. 28 U.S.C. §§ 1915(e)(2); 1915A. The Court has reviewed the Complaint and determined that it may fail to state a claim because it is Heck-barred or suffers from other pleading defects.

1 Page citations refer to pagination imposed by the Court’s electronic filing system. CIVIL MINUTES – GENERAL

Case No. 5:22-cv-01586-JAK-KES Date: May 19, 2023 Page 2

I. THE HECK BAR. A. Relevant Law. A § 1983 claim must be dismissed if “a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence,” unless that conviction or sentence has already been invalidated. Heck v. Humphrey, 512 U.S. 477, 487 (1994). “[I]f a criminal conviction arising out of the same facts stands and is fundamentally inconsistent with the unlawful behavior for which section 1983 damages are sought, the 1983 action must be dismissed.” Smithart v. Towery, 79 F.3d 951, 952 (9th Cir. 1996) (per curiam); see, e.g., Szajer v. City of Los Angeles, 632 F.3d 607, 611-12 (9th Cir. 2011) (holding Heck bars § 1983 Fourth Amendment claim challenging searches and seizures that led to convictions). Consequently, “the relevant question is whether success in a subsequent § 1983 suit would ‘necessarily imply’ or ‘demonstrate’ the invalidity of the earlier conviction or sentence.” Smith v. City of Hemet, 394 F.3d 689, 695 (9th Cir. 2005) (quoting Heck, 512 U.S. at 487). B. Plaintiff’s Trespassing Conviction. District courts “may take notice of proceedings in other courts, both within and without the federal judicial system, if those proceedings have a direct relation to matters at issue.” United States ex rel. Robinson Rancheria Citizens Council v. Borneo, Inc., 971 F.2d 244, 248 (9th Cir. 1992) (internal quotation marks and citation omitted) (taking judicial notice of the California Superior Court’s proceedings). The Court takes judicial notice of the SBC Superior Court records for case no. MSB21004039: The People of the State of California vs. BROQUE ANTHONY ANDERSON, Court Access Portal: Superior Court of California, County of San Berardino (May 17, 2023, 4:42 PM), cap.sb-court.org/case/NjgwNDcxOA==. According to those court records, a criminal case was initiated against Plaintiff on March 26, 2021, with the filing of a Sesslin Affadavit.2 Plaintiff was charged with a misdemeanor violation of California Penal Code section 602(o) which prohibits: Refusing or failing to leave land, real property, or structures belonging to or lawfully occupied by another and not open to the general public, upon being requested to leave by (1) a peace officer at the request of the owner, the owner’s agent, or the person in lawful possession, and upon being informed by the peace officer that they are acting at the request of the owner, the owner’s agent, or the person in lawful possession, or (2) the

2 A “Sesslin Affidavit” refers to a declaration of probable cause submitted by an arresting officer after a warrantless misdemeanor arrest. See People v. Sesslin, 68 Cal. 2d 418 (1968). CIVIL MINUTES – GENERAL

Case No. 5:22-cv-01586-JAK-KES Date: May 19, 2023 Page 3

owner, the owner’s agent, or the person in lawful possession. Plaintiff pled guilty on July 7, 2021, and a conviction was entered based on his guilty plea. He was sentenced to serve two days in the SBC jail. On April 19, 2023, Plaintiff filed a motion to vacate his plea and conviction. It appears that motion remains pending. C. Heck Analysis: Fourth Amendment Claims. Plaintiff alleges that the Deputy Defendants violated his Fourth Amendment rights by arresting him without probable cause while he was at the Holiday Inn. (Dkt. 1 at 5.) The Fourth Amendment protects individuals against “unreasonable searches and seizures” by the government. U.S. Const. amend. IV. An arrest without probable cause is an unreasonable seizure. Dubner v. City & County of San Francisco, 266 F.3d 959, 964 (9th Cir. 2001). Plaintiff also alleges that the Deputy Defendants searched his person and “property” he had with him when he was arrested. (Dkt. 1 at ___.) Searches conducted incident to a lawful arrest do not violate the Fourth Amendment. United States v. Robinson, 414 U.S. 218, 224 (1973). Plaintiff, however, suggests that the search conducted by Defendants was unconstitutional because his arrest was unlawful. To prevail on these Fourth Amendment claims, it appears that Plaintiff must attack the validity of his conviction in SBC Superior Court case no. MSB21004039. Per the above-cited records, this conviction has not yet been overturned, reversed, expunged, or otherwise invalidated. As a result, Plaintiff’s Fourth Amendment claims are foreclosed by Heck. D. Heck Analysis: Equal Protection Claims. “The Equal Protection Clause of the Fourteenth Amendment commands that no state shall ‘deny to any person within its jurisdiction the equal protection of the laws,’ which is essentially a direction that all persons similarly situated should be treated alike.” City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432, 439 (1985). Plaintiff alleges in conclusory fashion that Defendants denied him equal protection when they wrongfully arrested him. (Dkt. 1 at 1.) Plaintiff has failed to plead facts supporting this claim.

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Related

United States v. Robinson
414 U.S. 218 (Supreme Court, 1973)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Szajer v. City of Los Angeles
632 F.3d 607 (Ninth Circuit, 2011)
Smith v. City of Hemet
394 F.3d 689 (Ninth Circuit, 2005)
People v. Sesslin
439 P.2d 321 (California Supreme Court, 1968)
Dubner v. City & County of San Francisco
266 F.3d 959 (Ninth Circuit, 2001)

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Bluebook (online)
Broque Anthony Anderson v. San Bernardino Sheriffs Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/broque-anthony-anderson-v-san-bernardino-sheriffs-department-cacd-2023.