DeCastro v. Las Vegas Metropolitan Police Department

CourtDistrict Court, D. Nevada
DecidedOctober 23, 2023
Docket2:23-cv-00580
StatusUnknown

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

Bluebook
DeCastro v. Las Vegas Metropolitan Police Department, (D. Nev. 2023).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 JOSE DECASTRO, Case No. 2:23-cv-00580-APG-EJY

4 Plaintiff, Order Granting in Part Defendants’ v. Motion to Dismiss 5 LAS VEGAS METROPOLITAN POLICE [ECF No. 15] 6 DEPARTMENT, STATE OF NEVADA, BRANDEN BOURQUE, JASON TORREY, 7 C. DINGLE, B. SORENSON, JESSE SANDOVAL, and OFFICER DOOLITTLE,

8 Defendants.

10 Plaintiff Jose DeCastro sues the State of Nevada, the Las Vegas Metropolitan Police 11 Department (LVMPD), and several LVMPD officers: Branden Bourque, Jason Torrey, C. 12 Dingle, B. Sorenson, Jesse Sandoval, and C. Doolittle. DeCastro contends the officers 13 unreasonably searched and seized him because he was video recording a police encounter. 14 LVMPD, Bourque, Dingle, Sorenson, Sandoval, and Doolittle move to dismiss all claims except 15 DeCastro’s claim for excessive force under the Fourth Amendment and state law claims for 16 assault and battery. Torrey filed a joinder to the motion. DeCastro opposes dismissal or 17 alternatively requests leave to amend. I grant the motion in part, with leave to amend in part. 18 I. BACKGROUND 19 In March 2023, DeCastro observed an interaction between defendant Bourque and an 20 unknown woman, whom the complaint refers to as “Jane.” ECF No. 13 at 5. DeCastro began 21 recording the incident on his phone from approximately 10 feet away from Jane and asked her if 22 she was okay. Id. Bourque left his patrol car and told DeCastro to back up, which DeCastro did 23 by moving back another five feet. Id. at 6. Bourque told DeCastro to back up further, but 1 DeCastro stated that he had a right to be there and was a member of the press. Id. Bourque 2 threatened to detain DeCastro for obstructing and stated that Jane deserved privacy. Id. 3 DeCastro repeated that he was a member of the press, at which point Bourque indicated he was 4 detaining DeCastro. Id. Bourque told Jane to leave and then approached DeCastro. Id. Bourque 5 placed DeCastro under arrest, patted him down, and placed him in handcuffs. Id.

6 Three other officers arrived on the scene. Id. at 7. DeCastro continued to protest that the 7 officers had no valid reason to detain or arrest him. Id. According to the amended complaint, 8 “Bourque accused [DeCastro] of being on drugs based on the color of his skin.” Id. One of the 9 other officers told DeCastro to look only straight ahead, and when DeCastro did not immediately 10 comply, the officer squeezed his elbow. Id. DeCastro complained about the pain this caused and 11 about the order that he must look in only one direction. Id. The officer squeezing his elbow 12 stated that it was policy to squeeze the elbows of people who did not comply with orders. Id. 13 DeCastro alleges that he asked the other officers for help and told them that he would sue them 14 for failing to intervene, but they ignored him. Id. DeCastro claims his elbow was squeezed for

15 15 minutes before he could not tolerate it further and tore his elbow away from the officer. Id. at 16 7-8. 17 Torrey, who the amended complaint identifies as a supervisor, arrived on the scene. Id. at 18 8. According to the amended complaint, Torrey authorized the officers’ conduct and told 19 DeCastro that he should be arrested to discourage his behavior. Id. At some point during the 20 encounter, Bourque told DeCastro that First Amendment Auditors (people who record police 21 interactions) had been known to drop their recording device and pull out a weapon to fire at 22 officers. Id. 23 1 Another officer stated that DeCastro needed to be patted down, even though he had 2 already been patted down by two other officers. Id. According to the amended complaint, the 3 officer spread DeCastro’s legs uncomfortably wide and struck DeCastro in the testicles. Id. 4 DeCastro was then placed in the police car in an overly tight seat belt. Id. He was searched and 5 transported to the jail, but he was released about five hours later with citations. Id. He claims

6 that defendant Sorenson repeatedly threatened to charge DeCastro based on DeCastro’s dog 7 being left in a car during this incident. Id. at 8-9. DeCastro alleges that the officers acted the way 8 they did because DeCastro had recently covered stories about LVMPD that went viral on the 9 internet. Id. at 10. 10 Based on these allegations, DeCastro brings claims under 42 U.S.C. § 1983 for 11 unreasonable search and seizure, equal protection, and First Amendment retaliation against the 12 individual officers. He asserts entity and supervisory liability under § 1983 against the State of 13 Nevada, LVMPD, and Torrey. He asserts a claim of intentional race and political viewpoint 14 discrimination under 42 U.S.C. § 1981 against all the officers. He also brings state law claims

15 for assault, battery, false arrest and imprisonment, invasion of privacy, and negligence against all 16 the defendants. 17 II. ANALYSIS 18 Summary judgment is appropriate if the movant shows “there is no genuine dispute as to 19 any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 20 56(a). A fact is material if it “might affect the outcome of the suit under the governing law.” 21 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is genuine if “the evidence 22 is such that a reasonable jury could return a verdict for the nonmoving party.” Id. 23 1 The party seeking summary judgment bears the initial burden of informing the court of 2 the basis for its motion and identifying those portions of the record that demonstrate the absence 3 of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The 4 burden then shifts to the non-moving party to set forth specific facts demonstrating there is a 5 genuine issue of material fact for trial. Sonner v. Schwabe N. Am., Inc., 911 F.3d 989, 992 (9th

6 Cir. 2018) (“To defeat summary judgment, the nonmoving party must produce evidence of a 7 genuine dispute of material fact that could satisfy its burden at trial.”). I view the evidence and 8 reasonable inferences in the light most favorable to the non-moving party. Zetwick v. Cnty. of 9 Yolo, 850 F.3d 436, 440-41 (9th Cir. 2017). 10 A. Section 1983 11 “To state a claim under § 1983, the plaintiff must allege a violation of his constitutional 12 rights and show that the defendant’s actions were taken under color of state law.” Gritchen v. 13 Collier, 254 F.3d 807, 812 (9th Cir. 2001). The parties do not dispute that the defendants acted 14 under color of state law.

15 1. Fourth Amendment Seizure Based on the Arrest 16 The defendants contend DeCastro’s Fourth Amendment unreasonable seizure claim 17 based on the arrest fails because by the amended complaint’s allegations, the officers had 18 probable cause to arrest DeCastro for obstruction. They contend that DeCastro was too close to 19 the scene, was interacting with Jane who had no choice to avoid DeCastro because she was being 20 detained by the police, and would not back up when ordered to do so.

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DeCastro v. Las Vegas Metropolitan Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/decastro-v-las-vegas-metropolitan-police-department-nvd-2023.