Harrison v. City and County of San Francisco

CourtDistrict Court, N.D. California
DecidedSeptember 19, 2023
Docket4:20-cv-05178
StatusUnknown

This text of Harrison v. City and County of San Francisco (Harrison v. City and County of San Francisco) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrison v. City and County of San Francisco, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 PATRINA HARRISON, Case No. 20-cv-05178-JST

8 Plaintiff, ORDER GRANTING MOTION TO 9 v. DISMISS

10 CITY AND COUNTY OF SAN Re: ECF No. 108 FRANCISCO, 11 Defendant.

12 13 Before the Court is Defendant City and County of San Francisco’s motion to dismiss. ECF 14 No. 108. The Court will grant the motion. 15 I. BACKGROUND 16 Plaintiff Patrina Harrison is a San Francisco resident who suffers from physical disabilities. 17 ECF No. 107 ¶ 1. She resides at the Arnett Watson Apartments in the Tenderloin neighborhood of 18 San Francisco through the San Francisco Local Operating Subsidy Program, a federally funded 19 housing program. Id. ¶¶ 1, 17. 20 Harrison alleges that, in the wake of the COVID-19 pandemic, the City “purchas[ed] and 21 install[ed] homeless tent housing encampments” in the Tenderloin—including along the “walls 22 directly under the bedroom and living [room] windows” of her apartment. Id. ¶¶ 17, 18. On July 23 18, 2020, two City-installed tents caught fire, sending smoke directly into Harrison’s apartment, 24 triggering a severe asthma attack. Id. ¶ 35. Harrison submitted a request for reasonable 25 accommodation asking the City to remove the tents it installed under her window or to transfer her 26 to a building in a different neighborhood. Id. ¶ 36. Both requests were denied. Id. 27 Harrison then filed this suit against the City for violations of her rights under federal and 1 initial complaint with leave to amend. ECF No. 40. Over the following two years, Harrison filed 2 two additional amended complaints. ECF Nos. 59, 81. The City moved to dismiss each of these 3 complaints, and the Court granted both motions in part and denied both in part. ECF Nos. 80, 100. 4 On August 8, 2021, Harrison filed a second lawsuit based on similar claims, Harrison v. 5 City and County of San Francisco, 21-cv-6484-JST (Harrison II).1 On April 19, 2023, the Court 6 granted the City’s motion to consolidate both cases into Harrison I. ECF No. 100. Harrison filed 7 a consolidated amended complaint (“CAC”) on May 4, 2023. ECF No. 107. The City now moves 8 to dismiss all claims raised in the CAC except state law nuisance and negligence. ECF No. 108 at 9 6. 10 II. JURISDICTION 11 The Court has jurisdiction over Harrison’s federal law claims under 28 U.S.C. § 1331 and 12 exercises supplemental jurisdiction over Harrison’s state law claims under 28 U.S.C. § 1367. 13 III. LEGAL STANDARD 14 “Dismissal under [Federal Rule of Civil Procedure] 12(b)(6) is appropriate only where the 15 complaint lacks a cognizable legal theory or sufficient facts to support a cognizable legal theory.” 16 Mendiondo v. Centinela Hosp. Med. Ctr., 521 F.3d 1097, 1104 (9th Cir. 2008). “To survive a 17 motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a 18 claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting 19 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “Threadbare recitals of the elements of a 20 cause of action, supported by mere conclusory statements, do not suffice.” Id. 21 When ruling on a motion to dismiss, courts “accept all factual allegations in the complaint 22 as true and construe the pleadings in the light most favorable to the nonmoving party.” Knievel v. 23 ESPN, 393 F.3d 1068, 1072 (9th Cir. 2005). Pro se complaints must be liberally construed and 24 held to a less stringent standard than formal pleadings drafted by attorneys. Erickson v. Pardus, 25 551 U.S. 89, 94 (2007) (per curiam). 26

27 1 Because the facts of Harrison II are well-known to the parties and the Court has summarized 1 Leave to amend a complaint “shall be freely given when justice so requires.” Fed. R. Civ. 2 P. 15(a)(2). The decision of whether to grant leave to amend is “within the discretion of the 3 district court, which may deny leave due to ‘undue delay, bad faith or dilatory motive on the part 4 of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue 5 prejudice to the opposing party by virtue of allowance of the amendment, and futility of 6 amendment.’” Leadsinger, Inc. v. BMG Music Pub., 512 F.3d 522, 532 (9th Cir. 2008) (quoting 7 Foman v. Davis, 371 U.S. 178, 182 (1962)). 8 IV. DISCUSSION 9 The City moves to dismiss Harrison’s claims brought under 42 U.S.C. § 1983, the 10 Americans with Disabilities Act, the Rehabilitation Act, as well as her claim for violation of 11 California Civil Code § 3479. 12 A. Section 1983 13 Harrison brings claims under Section 1983 for violation of her rights under the Due 14 Process Clause and the Equal Protection Clause. 15 1. Due Process Claim 16 Harrison alleges that the City violated her due process rights pursuant to the state-created 17 danger doctrine by providing unhoused individuals with tents anchored to the sidewalk underneath 18 the windows of her apartment, and by providing these individuals with adulterated substances, 19 cigarettes, candles, and matches. ECF No. 107 ¶ 65. 20 This Court previously dismissed Harrison’s due process claims in Harrison I and Harrison 21 II with prejudice. In Harrison I, Harrison alleged that “the City violated her due process rights by 22 ‘installing the tents under her bedroom and living room windows . . . creat[ing] the danger’ to 23 her.” ECF No. 100 at 4 (quoting ECF No. 81 ¶ 48). After twice giving Harrison the opportunity 24 to amend her complaint, the Court dismissed this claim with prejudice. Id. It held that Harrison 25 failed to show “(1) that the City’s affirmative conduct exposed her to an actual, particularized 26 danger, placed her in a worse position than she would have been in had the City not acted at all, 27 and caused harm that was foreseeable; and (2) that the City acted with deliberate indifference to a 1 Similarly, in Harrison II, Harrison alleged that, by installing the tents, “Defendant acted 2 affirmatively in such a way . . . as to put [her] in a wors[e] position than that in which [she] would 3 have been . . . had the Defendant not acted at all.” ECF No. 106 at 4. Further, Harrison alleged 4 that when the City “refused [her] Reasonable Accommodation Request to move, or to relocate the 5 tents, this shows that Defendant took affirmative acts to create the condition [she] complains of.” 6 Id. The Court dismissed this claim without leave to amend because the allegation of additional 7 facts would be futile. Id. at 4–5. In so holding, it noted that when the City first installed the tents, 8 “any smoke- or explosive-related danger to Harrison was not known or obvious,” and that the 9 City’s denial of Harrison’s transfer requests was “not an affirmative act that placed Harrison in a 10 worse position than she would have been otherwise.” Id. at 4.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mark H. v. Hamamoto
620 F.3d 1090 (Ninth Circuit, 2010)
Mendiondo v. Centinela Hospital Medical Center
521 F.3d 1097 (Ninth Circuit, 2008)
Leadsinger, Inc. v. BMG Music Publishing
512 F.3d 522 (Ninth Circuit, 2008)

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Bluebook (online)
Harrison v. City and County of San Francisco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrison-v-city-and-county-of-san-francisco-cand-2023.