Dorsett v. The City of San Diego

CourtDistrict Court, S.D. California
DecidedFebruary 24, 2025
Docket3:24-cv-00813
StatusUnknown

This text of Dorsett v. The City of San Diego (Dorsett v. The City of San Diego) 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
Dorsett v. The City of San Diego, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 WILLIAM J. DORSETT, and Case No.: 24-cv-00813-AJB-AHG ROGELIO FLORES, 12 ORDER GRANTING IN PART AND Plaintiffs, 13 DENYING IN PART DEFENDANT’S v. MOTION TO DISMISS 14

THE CITY OF SAN DIEGO, and DOES 15 (Doc. No. 6.) 1-25, inclusive, 16 Defendants. 17 18 Before the Court is Defendant City of San Diego’s (“Defendant” or “City”) motion 19 to dismiss Plaintiffs William J. Dorsett and Rogelio Flores’s (“Plaintiffs”) First Amended 20 Complaint, (Doc. No. 5, “FAC”). (Doc. No. 6.) The motion is fully briefed. (See Doc. Nos. 21 6, 8, 9.) For the following reasons, the Court GRANTS IN PART and DENIES IN PART 22 Defendant’s motion to dismiss. 23 / / / 24 / / / 25 / / / 26 / / / 27 28 / / / 1 I. BACKGROUND 2 Plaintiffs are “buskers,” or street artists and performers. (FAC ¶ 1.) Plaintiff William 3 J. Dorsett paints and creates palm frond roses, “rose[es] made by hand from palm fronds,” 4 which he sells. (Id. ¶¶ 6, 51.) Plaintiff Rogelio Flores juggles and performs magic shows. 5 (Id. ¶ 7.) 6 Plaintiff Dorsett 7 A. Ocean Beach 8 On February 1, 2023, Dorsett was busking—painting and displaying his artwork for 9 sale on a display table—on a public sidewalk in Ocean Beach, San Diego. (Id. ¶ 15.) Three 10 City park rangers and three police officers approached him. (Id.) A park ranger informed 11 Dorsett that he had to move his art display and table from the sidewalk to a grassy location, 12 an area designated by the City for First Amendment activities, which Plaintiff alleges was 13 crowded with other vendors selling goods. (Id. ¶ 38.) Plaintiff also alleges that the park 14 rangers and police officers told him that his art was not speech protected by the First 15 Amendment because he offered his art for sale. (Id. ¶¶ 2, 22–24.) The park rangers issued 16 Dorsett a written Sidewalk Vending Administration Citation (“citation”) for 1) vending 17 without a permit in violation of San Diego Municipal Code (“SDMC”) § 36.0103, and 2) 18 vending on a sidewalk within 15 feet of a high-traffic bike and shared use path in violation 19 of SDMC § 36.0106(a)(11)(J). (Id. ¶ 17.)2 The citation instructs Dorsett to “obtain [a] 20 sidewalk vending permit for any vending activities.” (Doc. No. 5-1 (citing SDMC § 21 36.0103).) 22 / / / 23 / / / 24 25 1 The following facts are taken from Plaintiff’s FAC, which the Court construes as true for the limited purpose of resolving the instant motion. See Brown v. Elec. Arts, Inc., 724 F.3d 1235, 1247 (9th Cir. 2013). 26 2 SDMC § 36.0103 requires all sidewalk vendors to obtain a vending permit prior to vending on any 27 sidewalk. (FAC ¶ 18.) SDMC § 36.0106(a)(11)(J) states, in relevant part: “(a) No stationary sidewalk 28 vendor shall vend and no roaming sidewalk vendor shall stop to make sales in the following locations: … 1 B. El Prado, Balboa Park 2 On May 21, 2023, Dorsett was busking in El Prado in Balboa Park. (FAC ¶ 34.) El 3 Prado is a “historic public busking location,” comprised of an approximately 40-foot-wide 4 pedestrian throughfare “that opens into large areas, with large intersections.” (Id. ¶¶ 33– 5 34, 44.) While Dorsett was busking, a City park ranger “forced Dorsett, under threat of 6 citation,” to move from El Prado “to a secluded busking location[.]” (Id. ¶ 34.) The ranger 7 informed Dorsett that he was obstructing a public sidewalk and blocking a fire lane (id. 8 ¶ 44), yet Plaintiff alleges his “small painting set up . . . left ample room on the sidewalk 9 for members of the public to walk around him” (id.). On March 1, 2023, Dorsett observed 10 a People for the Ethical Treatment of Animals (PETA) demonstration, “tak[ing] up more 11 than 400-square-feet of a public walkway, also in the El Prado area of Balboa Park, in a 12 way that in fact did obstruct the public walkway.” (Id.) 13 From December 1-2, 2023, during December Nights in Balboa Park, Dorsett alleges 14 that he was not permitted to set up his art displays in El Prado, as he had done in December 15 2022. (Id. ¶ 65.) Dorsett alleges that because the City “forced him to set up outside of the 16 area of the [December Nights] event,” during the 2023 December Nights held from 17 December 1-2, 2023, he earned approximately $400 compared to the approximately $1,200 18 he earned during the 2022 December Nights held from December 2-3, 2022. (Id.) The same 19 vending ordinance was in effect during both the 2022 and 2023 December Nights events. 20 (Id.) 21 C. Comic Con 22 On July 18, 2023, a day prior to the start of the five-day San Diego Comic Con event 23 (“Comic Con”), the City Chief Park Ranger, Michael F. Ruiz, informed Dorsett that he was 24 only permitted to engage in expressive activities during Comic Con in a City-designated 25 area near the San Diego Convention Center, where Comic Con is held. (Id. ¶ 39.) Upon 26 arrival to the designated grassy area, Dorsett alleges that he observed it was “too small” to 27 accommodate buskers. (Id.) He also found that the grass was over-watered to the extent 28 that water was pooling on the sidewalk and the ground was muddy. (Id.) During the 2023 1 Comic Con event, Dorsett earned approximately one-third of the amount that he previously 2 earned at past Comic Con events from selling his art. (Id.) Dorsett alleges the City “overly 3 watered” the designated zone for buskers “to discourage buskers from engaging in 4 expressive activities during Comic Con.” (Id.) 5 Plaintiff Flores 6 A. El Prado, Balboa Park 7 Flores performs magic shows for the public for monetary donations. (Id. ¶¶ 53, 71.) 8 On several occasions in September 2022, and on May 29, 2023, while Flores was 9 performing his magic show in Balboa Park, on El Prado, park rangers informed him that 10 he could not perform on El Prado, and instead directed him to a City-designated “First 11 Amendment” area. (Id. ¶¶ 32, 35.) Flores alleges that his reach to the public while 12 performing at the designated “First Amendment” area was severely limited compared to 13 his reach on El Prado. (Id.) On November 16, 2023, Flores was busking in Balboa Park on 14 El Prado and a group of approximately twenty people gathered to watch him. (Id. ¶ 36.) 15 After his show concluded, a park ranger issued Flores three citations.3 (Id.) Flores alleges 16 that enforcement of the City’s vending ordinances led to the reduction of his earnings from 17 busking from approximately $250 per day to approximately $120 per day. (Id. ¶ 66.) 18 Sidewalk Vending Ordinance & Expressive Activity Ordinance 19 Plaintiffs challenge the constitutionality of two sets of City regulations. First, 20 Plaintiffs challenge Ordinance No. 21459, SDMC Chapter 3, Article 6, Division 1, 21 Sidewalk Vending (§§ 36.101-36.0116) (the “Sidewalk Vending Ordinance”), that 22 includes a vending permit requirement (SDMC § 36.0103), and a vending locations 23 provision (id. § 36.0106). (See Doc. No. 5-2.) The Sidewalk Vending Ordinance came into 24 effect on June 22, 2022, and requires all sidewalk vendors to obtain a vending permit prior 25 to vending on any sidewalk. (Id. § 36.0103(b).) Section 36.0106 additionally stipulates, 26 “[n]o stationary sidewalk vendor shall vend . . . within 15 feet of any . . . high-traffic 27

28 1 sidewalk . . . or high-traffic bike and shared use path.” (Id. § 36.0106 (a).) At the time 2 Plaintiffs were cited, the Sidewalk Vending Ordinance exempted “[a]ny vendor or 3 individual engaged solely in artistic performances, free speech, political or petitioning 4 activities, or engaged solely in vending of items constituting expressive activity protected 5 by the First Amendment . . . [.]” (Id.

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Dorsett v. The City of San Diego, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dorsett-v-the-city-of-san-diego-casd-2025.