Fouts v. Becerra

CourtDistrict Court, S.D. California
DecidedFebruary 23, 2024
Docket3:19-cv-01662
StatusUnknown

This text of Fouts v. Becerra (Fouts v. Becerra) 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
Fouts v. Becerra, (S.D. Cal. 2024).

Opinion

8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10

11 RUSSELL FOUTS, et al., Case No.: 19-cv-1662-BEN-JLB 12

Plaintiffs, 13 DECISION v. 14 ROB BONTA, in his official capacity as 15 Attorney General of the State of 16 California, 17 Defendant. 18 I. INTRODUCTION 19 This case is about a California law that makes it a crime to simply possess or carry 20 a billy.1 This case is not about whether California can prohibit or restrict the use or 21 possession of a billy for unlawful purposes. The law does not define a “billy.” 22 23 24 1 California Penal Code § 22210 states: 25 “. . . any person in this state who manufactures or causes to be manufactured, imports into the state, keeps for sale, or offers or exposes for sale, or who gives, lends, or possesses 26 any leaded cane, or any instrument or weapon of the kind commonly known as a billy, 27 blackjack, sandbag, sandclub, sap, or slungshot, is punishable by imprisonment in a county jail not exceeding one year or imprisonment pursuant to subdivision (h) of Section 28 1 Historically, the short wooden stick that police officers once carried on their beat was 2 known as a billy or billy club.2 The term remains vague today and may encompass a 3 metal baton, a little league bat, a wooden table leg, or a broken golf club shaft, all of 4 which are weapons that could be used for self-defense but are less lethal than a firearm. 5 Americans have an individual right to keep and bear arms, whether firearms or less 6 lethal arms.3 The Second Amendment to the United States Constitution “guarantee[s] the 7 individual right to possess and carry weapons in case of confrontation.”4 The Second 8 Amendment is incorporated against California through the Due Process Clause of the 9 Fourteenth Amendment.5 Some people have made the personal decision to not keep and 10 carry a deadly firearm for self-defense. Instead, they sometimes wish to keep or carry a 11 less lethal arm for self-defense. Plaintiffs are two such citizens. 12 Plaintiffs desire to keep and carry a billy or baton for self-defense, but the State 13 considers that against the best interests of the State and defines it as a serious crime. 14 Perhaps an allegory may illustrate the constitutional defect in the statute Plaintiffs’ 15 challenge: 16 A young girl is walking home from school one evening. She is walking through a 17 part of town where robberies, assaults, and rapes have occurred; where youth gangs are 18 known to frequent; and where unrestrained dogs are known to roam. 19 The young girl is wearing a baggy, oversized sweatshirt sometimes associated with 20 gang affiliation. In her hand, she is holding a billy—a baton just like the ones law 21 enforcement officers often carry for their protection. An officer sees her walking and 22 sees that she is in possession of the baton. The officer arrests her for violating California 23 24 25 26 2 See Fouts v. Bonta, 561 F. Supp. 3d 941, 951–53 (S.D. Cal. 2021). 27 3 District of Columbia v. Heller, 554 U.S. 570, 630 (2008). 4 Id. at 606. 28 1 Penal Code § 22210. She is handcuffed, placed in the back of a police car, transported to 2 the police station, booked, fingerprinted, and initiated into the juvenile court system. 3 Although there is no evidence that she has ever struck or threatened to strike 4 anyone with the baton or that she is in danger of hurting herself with it, her mere 5 possession of it is enough. That she was in possession of the billy to protect herself in 6 self-defense from human or animal predators is not determinate. It is irrelevant. And 7 why does California elect to make this girl a criminal? Because there is a risk, no matter 8 how small, that the girl might use it for an unlawful purpose, or that others may use 9 similar weapons for unlawful purposes. The United States Constitution prohibits such 10 intrusions into an otherwise law-abiding citizen’s choice for self-defense. 11 The plaintiff in Caetano v. Massachusetts, 577 U.S. 411 (2016), used a less than 12 lethal stun gun to protect herself. The Supreme Court held that her use of the stun gun 13 was protected by the Second Amendment for her self-defense. “By arming herself, 14 Caetano was able to protect against a physical threat that restraining orders had proved 15 useless to prevent. And, commendably, she did so by using a weapon that posed little, if 16 any, danger of permanently harming either herself or the father of her children.” Id. at 17 413 (Alito, J. concurring). If our hypothetical schoolgirl or the Plaintiffs in California 18 choose to have a billy for self-defense, they will find themselves in the same unenviable 19 position of Ms. Caetano, who “[u]nder Massachusetts law . . . Caetano’s mere possession 20 of the stun gun that may have saved her life made her a criminal.” Id. 21 Though California Penal Code § 22210 criminalizes the possession of a less lethal 22 billy for self-defense, federal courts protect the Constitution, and the Constitution 23 protects this citizen choice. The Second Amendment, “is the very product of an interest 24 balancing by the people and it surely elevates above all other interests the right of law- 25 abiding, responsible citizens to use arms for self-defense.”6 The American tradition is 26 27 28 1 rich and deep in protecting a citizen’s enduring right to keep and bear common arms, 2 whether they be rifles, shotguns, pistols, knives, or less lethal arms like stun guns and 3 billies. It is “this balance—struck by the traditions of the American people—that 4 demands our unqualified deference.”7 5 II. REMAND FOR BRUEN REVIEW 6 Previously, summary judgment was entered in favor of Defendant and the case was 7 appealed.8 That decision was based on the conclusion that the state statute (in effect 8 since 1923) was “longstanding,” and because it was deemed “longstanding” under older 9 circuit precedent, no further historical inquiry was to be done.9 For example, in Silvester 10 v. Harris, 843 F.3d 816 (9th Cir. 2016), a state statute imposing a firearm purchase 11 waiting period in existence since 1923 was thought of as sufficiently longstanding. In the 12 same way, Fyock v. City of Sunnyvale, 779 F.3d 991, 997 (9th Cir. 2014), suggested that 13 several state statutes from the early twentieth century might nevertheless demonstrate a 14 longstanding regulation. This was the precedent that the Ninth Circuit had decided, and 15 this was the precedent this Court followed. After these decisions, the Supreme Court 16 decided Bruen. 17 This case was remanded from the United States Court of Appeals for the Ninth 18 19 20 21 22 7 Id. 23 8 Fouts, 561 F. Supp. 3d at 941. 9 Id. at 945–46 (“This Court agrees that Cal. Penal Code § 22210 is a longstanding 24 regulation. Under Ninth Circuit precedent, that ends the matter.”); id. at 948 (describing 25 the one-step analysis for longstanding regulations set out in Young v. Hawaii, 992 F.3d 765, 783 (9th Cir. 2021) (en banc)) (“Laws restricting conduct that can be traced to the 26 founding era and are historically understood to fall outside of the Second Amendment’s 27 scope may be upheld without further analysis. Accordingly, a regulation does not burden conduct protected by the Second Amendment if the record contains evidence that the 28 1 Circuit specifically to consider the challenged law in light of Bruen. Under Bruen, the 2 government must affirmatively prove that its criminal statute prohibiting possession of a 3 billy is part of our historical traditions.

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Fouts v. Becerra, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fouts-v-becerra-casd-2024.