Emily Bauer v. Presidio Residences, et al.

District Court, N.D. California·Decided March 20, 2026·No. 3:25-cv-07496·Unknown

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 EMILY BAUER, 10 Case No. 25-cv-07496-RS Plaintiff, 11 v. ORDER GRANTING DEFENDANTS’ 12 MOTION TO DISMISS WITH LEAVE PRESIDIO RESIDENCES, et al., TO AMEND 13 Defendants. 14

15 Plaintiff Emily Bauer sued various federal defendants under the Federal Tort Claims Act 16 (FTCA), broadly averring that the residential property she rented from the Presidio Trust was unfit 17 for human habitation. Defendants move to dismiss, arguing that subject matter jurisdiction over 18 the suit is absent because Bauer failed to comply with various requirements in the FTCA and 19 associated regulations. The motion is suitable for disposition without oral argument. See Civ. L. R. 20 7-1(b). Defendants are correct that Bauer has failed to name the only proper defendant in an FTCA 21 suit: the United States. However, the bulk of their other arguments in favor of dismissal fail. 22 Therefore, the motion is granted with leave to amend. 23 I. BACKGROUND 24 Emily Bauer began renting a residential property in the Presidio of San Francisco around 25 2010. Her most recent lease agreement was executed on March 30, 2021. See Complaint ¶ 12. The 26 Presidio is owned and operated by the federal government through the Presidio Trust. See 27 Omnibus Parks and Public Lands Management Act, Pub. L. 104-333 (Nov. 12, 1996). The 1 the John Stewart Company to manage those leasing operations. Bauer’s lease agreement listed her 2 landlord as “Presidio Trust, by and through its agent, the John Stewart Company,” and listed her 3 landlord’s address as 222 Halleck Street in San Francisco. See Complaint, Ex. A. 4 At some point after tenancy began, Bauer avers that she started experiencing problems 5 with her unit. Those problems included rodent infestations, mold, and exposed wiring. See 6 Complaint ¶ 14. Bauer attempted to inform her landlord of the issues with her unit at least twice. 7 On March 5, 2023, Bauer’s attorney sent an email to the address “Presidio@presidiotrust.gov.” 8 That email attached a letter, addressed to “Presidio Trust,” which laid out the basic contours of the 9 issue and contended that the Presidio Trust’s exposure “exceeds $100,000.00.” Martin Decl., Ex. 10 B. On June 14, 2023, Bauer’s attorney sent another message to three email addresses—one of 11 which was Presidio@presidiotrust.gov. See Chan Decl., Ex. C. That communication was directed 12 at four potential “defendants”—one of which was the Presidio Trust—and was styled as a 13 “settlement proposal.” Id. It extensively recited the alleged defects in her unit and catalogued the 14 various damages she sought to recover. See id. The damages included rent differential, a refund of 15 rent paid, out-of-pocket expenses incurred, property damage, and emotional injury. See id. It 16 calculated total “economic, noneconomic, and statutory damages” to be $215,722.50 but offered to 17 settle the matter for $150,000. See id. 18 The dispute did not resolve, so Bauer filed this lawsuit. She asserts eight causes of action, 19 all broadly related to the Defendants’ provision of a defective apartment unit. She invoked federal 20 jurisdiction under the FTCA. See 28 U.S.C. § 1346(b). Defendants have moved to dismiss for 21 want of jurisdiction. 22 II. LEGAL STANDARD 23 Defendants move to dismiss under Federal Rules of Procedure 12(b)(1) and 12(b)(6). The 24 former permits dismissal for lack of subject matter jurisdiction. See Fed. R. Civ. P. 12(b)(1). The 25 latter permits dismissal for failure to state a claim upon which relief can be granted. See Fed. R. 26 Civ. P. 12(b)(6). To survive a motion to dismiss under Rule 12(b)(6), the complaint must allege 27 sufficient facts which, if accepted as true, “state a claim for relief that is plausible on its face.” Bell 1 Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the 2 plaintiff pleads factual content that allows the court to draw the reasonable inference that the 3 defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 4 “Where a complaint pleads facts that are ‘merely consistent with’ a defendant’s liability, it ‘stops 5 short of the line between possibility and plausibility of entitlement to relief.’” Id. (quoting 6 Twombly, 550 U.S. at 557). 7 III. DISCUSSION 8 a. Jurisdiction 9 Bauer filed her complaint against the Presidio Trust, Presidio Residences, and several Doe 10 defendants. However, “the only proper party defendant in an FTCA action” is the United States. 11 Kennedy v. United States Postal Service, 145 F.3d 1077, 1078 (9th Cir. 1998). Because Bauer has 12 sued the wrong defendant, dismissal is appropriate. She is given leave to amend her complaint to 13 fix this deficiency. 14 Beyond suing the wrong party, Defendants make several arguments for why there is no 15 subject-matter jurisdiction over this suit. First, they contend that Bauer failed to present properly 16 an administrative tort claim to the Presidio Trust. 28 U.S.C. section 2675(a) requires an FTCA 17 plaintiff to “first present[] the claim to the appropriate Federal agency.” This exhaustion 18 requirement is jurisdictional. See id. (providing that “[a]n action shall not be instituted” unless it 19 has been exhausted with the agency). 20 By sending multiple emails through her counsel to the Presidio Trust, Bauer “presented the 21 claim to the appropriate Federal agency.” 28 U.S.C. § 2675(a). The regulations specifically 22 governing the Presidio Trust say only that “[c]laims shall be filed directly with the Presidio Trust.” 23 36 C.F.R. § 1009.2(b). The Defendants contend that “[t]he Presidio Trust does not represent to the 24 public that it accepts administrative tort claim submissions at the email address of 25 Presidio@presidiotrust.gov,” but it is unclear where it does accept such submissions. Though the 26 regulations say a claimant must go directly to the Presidio Trust, they do not specify a mechanism, 27 and the only address in the regulations is buried in a separate section covering the procedure for 1 obtaining employee testimony or Presidio Trust records. See 36 C.F.R. § 1012.3(d). Absent more 2 specific guidance, a general purpose email address was a perfectly reasonable place for Bauer to 3 present her complaint, fully satisfying her obligation under the statute. Defendants protest that the 4 Presidio Trust’s counsel reached out to inform Bauer’s counsel that emailed submissions did not 5 constitute a valid administrative complaint, but that proves too much. The Presidio Trust patently 6 had notice of the complaint, and it is the statute and the governing regulations—not the 7 proclivities of the agency’s counsel—that determine what constitutes valid presentation. 8 Second, Defendants contend Bauer’s emails failed to include a “sum certain” for her claim. 9 Under Ninth Circuit precedent, “section 2675(a) requires the claimant or his legal representative to 10 file . . . a sum certain damages claim.” Warren v. United States Dept.

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Emily Bauer v. Presidio Residences, et al., (N.D. Cal. 2026).

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