Harris v. City of San Diego, San Diego Police Department

CourtDistrict Court, S.D. California
DecidedAugust 14, 2023
Docket3:23-cv-00739
StatusUnknown

This text of Harris v. City of San Diego, San Diego Police Department (Harris v. City of San Diego, San Diego Police Department) 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
Harris v. City of San Diego, San Diego Police Department, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 KEITH WARREN HARRIS, Case No.: 23cv739-LL-SBC

12 Plaintiff, ORDER GRANTING MOTION TO 13 v. REMAND [ECF No. 5] 14 CITY OF SAN DIEGO, SAN DIEGO POLICE DEPARTMENT AND OFFICER 15 CHAD LUCAS, 16 Defendants. 17 18 This matter is before the Court on Plaintiff Keith Harris’ Motion to Remand. ECF 19 No. 5. Defendants, City of San Diego, San Diego Police Department and Officer Chad 20 Lucas, filed an Opposition [ECF No. 10]. The Motion is fully briefed, and the Court deems 21 it suitable for submission without oral argument. For the reasons set forth below, the Court 22 GRANTS the Motion. 23 I. Background 24 Plaintiff, proceeding pro se, filed this lawsuit in San Diego County Superior Court, 25 and the original complaint was filed on February 21, 2023. ECF No. 1-4. The original 26 complaint asserted eleven causes of action arising from an incident that Plaintiff alleges 27 resulted in him being unlawfully detained by Officer Lucas. Id. at ¶¶ 4-10. Defendants 28 subsequently removed the case to this Court pursuant to 28 U.S.C. Section 1331 in light of 1 the “civil rights claims under 42 U.S.C. Section 1983, the Fourth Amendment, as well as a 2 Monell municipal liability claim under 42 U.S.C. Section 1983.” Notice of Removal at 3 ECF No. 1 at 2. On April 28, 2023, Defendants filed a Motion to Dismiss and Motion to 4 Strike Plaintiff’s Complaint under Federal Rules of Civil Procedure 12(b)(6) and 12(f). 5 ECF No. 3. Less than one month later, on May 17, 2023, Plaintiff filed a Motion for Leave 6 to Amend his Complaint and to Remand the Action to State Court. ECF No. 5. On May 7 22, 2023, the Court granted Plaintiff’s Motion for Leave to Amend and denied as moot the 8 pending Motion to Dismiss and Motion to Strike. ECF No. 6. Plaintiff filed his amended 9 complaint on the same day that the Court granted leave to amend. ECF No. 7. Plaintiff’s 10 First Amended Complaint (“FAC”) alleges eleven causes of action like the original 11 complaint, but replaces the two federal causes of action from the original complaint with 12 state claims. Specifically, Plaintiff replaced the Monell municipal liability claim under 42 13 U.S.C. § 1983 with a claim for vicarious liability. ECF No. 7 at ¶¶ 61-63. Plaintiff’s FAC 14 also replaced the Fourth Amendment claim with a claim for Violation of California’s 15 Constitution Article I § 13. ECF No. 7 at ¶¶ 73-75. 16 II. Legal Standards 17 “Federal courts are courts of limited jurisdiction. They possess only that power 18 authorized by Constitution and statute. . . .” Kokkonen v. Guardian Life Ins. Co. of Am., 19 511 U.S. 375, 377 (1994). It is “presume[d] that federal courts lack jurisdiction unless the 20 contrary appears affirmatively from the record.” Renne v. Geary, 501 U.S. 312, 316 (1991) 21 (internal quotation marks and citation omitted). “The right of removal is entirely a creature 22 of statute and a suit commenced in a state court must remain there until cause is shown for 23 its transfer under some act of Congress.” Syngenta Crop Protection, Inc. v. Henson, 537 24 U.S. 28, 32 (2002) (internal quotation marks and citation omitted). “The burden of 25 establishing federal jurisdiction is upon the party seeking removal. . . . ” Emrich v. Touche 26 Ross & Co., 846 F.2d 1190, 1195 (9th Cir. 1988). Moreover, courts must “strictly construe 27 the removal statute against removal jurisdiction.” Gaus v. Miles, Inc., 980 F.2d 564, 566 28 1 (9th Cir. 1992). Therefore, “[f]ederal jurisdiction must be rejected if there is any doubt as 2 to the right of removal in the first instance.” Id. 3 Pursuant to 28 U.S.C. § 1331, this Court has original jurisdiction over civil actions 4 “arising under” federal law. “A case ‘arises under’ federal law either where federal law 5 creates the cause of action or ‘where the vindication of a right under state law necessarily 6 turn[s] on some construction of federal law.’” Republican Party of Guam v. Gutierrez, 277 7 F.3d 1086, 1088–89 (9th Cir. 2002) (quoting Franchise Tax Bd. v. Constr. Laborers 8 Vacation Trust, 463 U.S. 1, 8–9 (1983)). “The presence or absence of federal-question 9 jurisdiction is governed by the ‘well-pleaded complaint rule,’ which provides that federal 10 jurisdiction exists only when a federal question is presented on the face of the plaintiff's 11 properly pleaded complaint.” Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987). 12 III. Discussion 13 A. Summary of Parties’ Arguments 14 Plaintiff argues that this case should be remanded because it “was originally filed in 15 State Court but mistakenly alleged two federal causes of action.” ECF No. 5 at 7. Plaintiff 16 further asserts that in light of the FAC, “this case no longer presents any federal question, 17 and the federal court lacks subject matter jurisdiction.” Id. 18 Defendants oppose Plaintiff’s Motion to Remand on the grounds that “Plaintiff’s 19 efforts are an unapologetic effort to forum shop.” ECF No. 10 at 3. Defendants 20 acknowledge in the Opposition that Plaintiff “substituted a claim under the California 21 Constitution for his existing Fourth Amendment claim” and that he “dismissed his Monell 22 claim in favor of an untethered vicarious liability claim under California Government Code 23 section 815.2(a).” Id. Notwithstanding these acknowledgements that Plaintiff’s federal 24 claims were amended and replaced with state claims, Defendants still argue that the “FAC 25 continues to allege multiple violations of federal rights and laws (ECF No. 7 at ¶¶ 28, 35, 26 41, 72).” ECF No. 10 at 3. In sum, Defendants argue that “[t]his Court should retain 27 supplemental jurisdiction over the action based on the continued invocation of federal 28 rights.” Id. 1 B. Analysis 2 As an initial matter, the court has an obligation where the plaintiff “is pro se, 3 particularly in civil rights cases, to construe the pleadings liberally and to afford the 4 [plaintiff] the benefit of any doubt.” Hebbe v. Pliler, 627 F.3d 338, 342, n.7 (9th Cir. 5 2010) (quoting Bretz v. Kelman, 773 F.2d 1026, 1027 n.1 (9th Cir. 1985)). Based on the 6 Court’s review of the FAC, it alleges only state law causes of action. Defendants have not 7 met their burden to show that the FAC still alleges multiple violations of federal rights. 8 The mere mention of federal laws in a paragraph of the complaint captioned as a state law 9 cause of action is not enough to convert that cause of action into a federal count.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Graham v. John Deere Co. of Kansas City
383 U.S. 1 (Supreme Court, 1966)
Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
Renne v. Geary
501 U.S. 312 (Supreme Court, 1991)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Hebbe v. Pliler
627 F.3d 338 (Ninth Circuit, 2010)
Sanford v. MemberWorks, Inc.
625 F.3d 550 (Ninth Circuit, 2010)
Millar v. Bay Area Rapid Transit District
236 F. Supp. 2d 1110 (N.D. California, 2002)
Horne v. Wells Fargo Bank, N.A.
969 F. Supp. 2d 1203 (C.D. California, 2013)
Emrich v. Touche Ross & Co.
846 F.2d 1190 (Ninth Circuit, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
Harris v. City of San Diego, San Diego Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-city-of-san-diego-san-diego-police-department-casd-2023.