Edwards v. City of San Diego

CourtDistrict Court, S.D. California
DecidedMay 16, 2025
Docket3:24-cv-01118
StatusUnknown

This text of Edwards v. City of San Diego (Edwards v. 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
Edwards v. 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 CAMERON EDWARDS, Case No.: 3:24-cv-01118-JAH-SBC

12 Plaintiff, ORDER DENYING PLAINTIFF’S 13 v. MOTION FOR A TEMPORARY RESTRAINING ORDER 14 CITY OF SAN DIEGO; et al.,

15 Defendants. [ECF Nos. 32, 33] 16 17 Pending before the Court is Plaintiff Cameron Edwards’s (“Plaintiff”) motion for a 18 temporary restraining order (“TRO”) filed on April 29, 2025. ECF No. 33. Plaintiff 19 requests that this Court issue a TRO directing the City of San Diego to issue an order 20 providing specific guidance to the San Diego Police Department on how police officers 21 engage in the “dominant aggressor” determination when responding to a domestic violence 22 dispute as required by the California Penal Code. ECF No. 33-1 at 14. 23 BACKGROUND 24 Plaintiff maintains that he left an abusive relationship in March 2024 and obtained a 25 domestic violence restraining order against his abuser. Id. at 2-3. Plaintiff contends that 26 on April 16, 2024, three domestic violence incidents occurred where officers of the San 27 Diego Police Department became involved. Id. at 3. In all three incidents, Plaintiff argues 28 officers did not consider the dominant aggressor factors under California Penal Code 1 §§ 836(c) and 13701, and instead took actions against Plaintiff under the City of San 2 Diego’s Procedure 4.04. According to Plaintiff, the officers (1) did not conduct a dominant 3 aggressor analysis and produced a written report that did not consider the dominant 4 aggressor analysis or mention the term at all, (2) entered Plaintiff’s home without his 5 consent and based on the purported consent of Plaintiff’s abuser, and proceeded to question 6 Plaintiff, and (3) spoke with Plaintiff’s abuser and indicated that Plaintiff was at his 7 residence, allowing the abuser to monitor Plaintiff. Id. at 3. In applying for a TRO from 8 this Court, Plaintiff argues that the dominant aggressor factors present in the California 9 Penal Code place a mandatory duty on police officers within the state,1 that the inconsistent 10 application of domestic violence policies by police departments frustrates the legislative 11 intent and plain language of California Penal Code §§ 13701 and 836, and that the injury 12 Plaintiff suffers is the lack of compliance by the San Diego Police Department with state 13 law. Id. at 8. Plaintiff also notes that this Court denied his motion for a preliminary 14 injunction on December 6, 2024, wherein Plaintiff sought relief “requiring the City of San 15 Diego [to] amend Procedure 4.04 to include consideration of all the factors listed in the 16 dominant aggressor procedure found in P.C. §§ 137901 and 836.” Id. at 3-4. 17 LEGAL STANDARD 18 Pursuant to Rule 65 of the Federal Rules of Civil Procedure, the Court may grant a 19 TRO to prevent “immediate and irreparable injury.” FED. R. CIV. P. 65(b). The purpose of 20 a TRO is to serve as a temporary remedy that prevents irreparable harm before a 21 preliminary injunction hearing may be held. Granny Goose Foods, Inc. v. Bhd. of 22 Teamsters & Auto Truck Drivers, 415 U.S. 423, 439 (1974). The legal standard that applies 23 to a motion for a TRO is the same as the one applied in a motion for a preliminary 24 25 1 The four factors police officers must make reasonable efforts to analyze include: (1) the 26 intent of the law to protect victims of domestic violence from continuing abuse, (2) the 27 threats creating fear of physical injury, (3) the history of domestic violence between the persons involved, and (4) whether either person acted in self-defense. CAL. PEN. CODE 28 1 injunction. Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832, 839 n.7 (9th 2 Cir. 2001). An applicant seeking a TRO is required to demonstrate “immediate and 3 irreparable injury, loss, or damage.” FED. R. CIV. P. 65(b)(1)(A). “Speculative injury does 4 not constitute irreparable injury” for the purposes of granting injunctive relief. Caribbean 5 Marine Serv. Co., Inc. v. Baldrige, 844 F.2d 668, 674 (9th Cir. 1988). The applicant cannot 6 demonstrate immediate injury when (1) purported harm to the applicant relies on the future 7 conduct of third parties and (2) the applicant cannot demonstrate immediate risk of injury 8 by those third parties. City of Los Angeles v. Lyons, 461 U.S. 95, 106-107 (1983). 9 DISCUSSION 10 Plaintiff contends he faces an imminent threat of the application of Procedure 4.04 11 by the San Diego Police Department and imminent harm from the police officers who will 12 respond to a future domestic altercation involving the Plaintiff. ECF No. 33-1 at 11. 13 Plaintiff alleges that he is now dating. Id. Plaintiff also cites to national statistics 14 purporting to show that a significant proportion of males who were identified as victims in 15 prior domestic violence incidents, and who were involved in new domestic violence 16 incidents, were subsequently identified by police as suspects. Id.2 Plaintiff also contends 17 that in half of domestic violence disputes in San Diego, police officers failed to interview 18 both parties as mandated by law. Id. at 12. 19 A. Imminent Harm 20 Plaintiff’s allegations of imminent harm require multiple steps involving third 21 parties, including (1) that Plaintiff will be involved in an altercation with his partner, (2) 22 that the police will be called, (3) that the police will apply Procedure 4.04 and misidentify 23 the dominant aggressor, and (4) the police will tangibly harm Plaintiff. Plaintiff has made 24 25 26 2 Plaintiff seeks judicial notice of statistics, his stated ownership of a dog at issue in this 27 matter, and caselaw. ECF No. 32. Even if the Court were to take judicial notice of those items, it would not change the result of this decision. Plaintiff’s request for judicial 28 1 no showing that he faces immediate harm and injury from the police absent an injunction. 2 Instead, Plaintiff has demonstrated that he may, at some point in the future, have a domestic 3 dispute with his partner that involves the police, and the police may wrongfully identify 4 Plaintiff as the dominant aggressor under Procedure 4.04 and then proceed to seize and 5 search him. The threat of conduct that may be taken by police officers at some point in the 6 future, as presented by Plaintiff, does not provide the Court with the “immediate and 7 irreparable injury, loss, or damage” necessary for issuance of a TRO. FED. R. CIV. P. 8 65(b)(1)(A).3 9 “[A]ny future threat to [Plaintiff] from the City’s policy or from the conduct of police 10 officers would be no more real than the possibility that he would again have an encounter 11 with the police” and that responding officers either apply the written policy, Procedure 12 4.04, and correctly distinguish the dominant aggressor from the victim, or apply Procedure 13 4.04 and incorrectly identify Plaintiff as the dominant aggressor, and then cause harm to 14 the Plaintiff (either by wrongfully seizing the Plaintiff or harming his property interests). 15 See Lyons, 461 U.S. at 106. Instead of being “immediate,” these threats are based on a 16 17 3 Plaintiff contends that the written policy and harm he faces are sufficient to demonstrate 18 that an injury is likely to recur for purposes of obtaining injunctive relief.

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