Hedayatzadeh v. City of Del Mar

District Court, S.D. California·Decided December 30, 2020·No. 3:19-cv-00842·Unknown

Opinion

KAHILA H. HEDAYATZADEH, Case No.: 19-cv-842-BEN (BLM)

Plaintiff, ORDER DENYING PLAINTIFF’S v. MOTION FOR LEAVE TO ADD ADDITIONAL CLASS PLAINTIFF

Defendant. [ECF No. 30] This matter comes before the Court on Plaintiff Kahlia H. Hedayatzadeh’s (“Plaintiff”) Motion Requesting Leave of Court to Amend the Class Action Complaint and Add an Additional Lead Plaintiff. ECF No. 30. For the reasons set forth below the motion is DENIED. Plaintiff alleges Defendant City of Del Mar, California, violated her Fourth Amendment rights by applying chalk marks on the tire of her vehicle to enforcing parking space time limits. Compl., ECF No. 1, ¶ 24. Plaintiff alleged that between May 3, 2017, and May 3, 2019, she received “at least one or two parking tickets” for exceeding the time limit on parking spots imposed in the City of Del Mar. Pl.’s Decl., ECF. No. 19-4, ¶ 2-3. She further alleged Defendant regularly and systematically uses a process of “chalking,” which consists of applying a small chalk mark to a car tire, to determine whether a car has over-stayed the parking spot time limit. Compl., ECF No. 1, ¶ 22-23. Plaintiff alleged Defendant chalks vehicles without consent, purportedly violating the Fourth Amendment’s prohibition on unreasonable searches and seizures. Id. at ¶ 24. Defendant admits it uses chalking to enforce parking regulations but denies that chalking violates the Fourth Amendment. Opp’n., ECF No. 20, at 2. While Plaintiff alleged she received “at least one or two” parking tickets, she has “not yet been able to locate any copies of these tickets.” Pl.’s Decl., ECF No. 19-4, ¶ 3. To this end, substantial discovery has already occurred. Opp’n, ECF No. 20, 2. Defendant has located and produced records for thousands of individuals cited during the applicable time frame. Id. Defendant has likewise searched for and produced corresponding payment records for those thousands of citations. Id. Despite this substantial effort, there is no record Defendant ever issued a ticket to Plaintiff, and no record Plaintiff ever paid a parking ticket to Defendant. Nonetheless, Plaintiff sought to certify a class of at least 5,500 people who have had their tires chalked and a subclass of at least 4,000 people who have allegedly paid parking tickets. Mot., ECF No. 19, 6-13. On July 23, 2020, the Court denied her motion for class certification. Order, ECF No. 23. The Court found that she did not meet the typicality requirement of Federal Rule of Civil Procedure 23(a) such that she would be a proper representative party because her standing in this case was so tenuous that it threatened to become the focal point of the litigation. Id. at 7. Based only on her pleadings, the Court agreed Plaintiff had alleged standing, but it also expressed serious doubt that Plaintiff would be able to prove her standing at later stages of litigation when the Court looked beyond the pleadings for evidence supporting her injury in fact. Id. Enter Kaveh Hedayatzadeh, Plaintiff’s brother, who – only one month after the Court’s order denying class certification – happened to receive a parking ticket from Defendant, allegedly based on Defendant’s use of chalking on his car tire. Mot., ECF No. 30, 2. Kaveh Hedayatzadeh has a copy of his citation, which he allegedly paid. Khashayar Decl., ECF No. 30-1, Ex. A. Plaintiff asks the Court to grant her leave to amend her Complaint, adding her brother as an additional representative plaintiff. Id. Defendant opposes, arguing (1) Plaintiff’s lack of standing bars amendment, and (2) the factors set forth in Foman v. Davis, 371 U.S. 178 (1962), weigh against granting leave to amend. Once a defendant has answered, a plaintiff may only amend the complaint by leave of court, or with the written consent of the adverse party. Fed. R. Civ. P. 15(a). Pursuant to Federal Rule of Civil Procedure 15(a)(2), leave to amend should be “freely given when justice so requires.” Foman, 371 U.S. at 182. “The power to grant leave to amend, however, is entrusted to the discretion of the district court, which determines the propriety of a motion to amend by ascertaining the presence of any of four factors: bad faith, undue delay, prejudice to the opposing party, and/or futility.” Serra v. Lappin, 600 F.3d 1191, 1200 (9th Cir. 2010) (quotation marks and citation omitted). Generally, amendments adding claims are granted more freely than amendments adding parties. Union Pacific R.R. Co. v. Nevada Power Co., 950 F.2d 1429, 1432 (9th Cir. 1991). Plaintiff argues amendment is appropriate here because her brother, Kaveh Hedayatzadeh, actually has a record of his parking citation, alleviating the “typicality” issues that plagued Plaintiff’s Motion for Class Certification. Mot., ECF No. 30, 6. She further argues her Motion to Amend (1) is made in good faith, (2) is timely following the Court’s ruling on her Motion for Class Certification, (3) does not unduly prejudice Defendant, and (4) would not be futile. Id. at 6-9. Defendant opposes, arguing that Plaintiff’s “lack of standing bars amendment,” and that the four Foman factors described above counsel against granting leave to amend. Opp’n, ECF No. 31, 4-11. A. Amendment cannot be made to cure lack of standing Plaintiff’s “typicality” argument is a guise that acknowledges her standing issues, and the Court has dealt with such matters before. See Evenchik v. Avis Rent A Car Sys., LLC, No. 12-cv-0061-BEN-DHB, 2013 WL 2301224 (S.D. Cal. May 24, 2013) (denying leave to amend that sought to ward off a potential challenge to the named plaintiff’s standing by adding another plaintiff). Here, as in Evenchik, Plaintiff seeks to amend her Complaint “to correct the shortcoming identified by adding an additional Plaintiff.” Mot., ECF No. 30, 2. As in Evenchik, the “shortcoming identified” is the named Plaintiff’s standing. 2013 WL 2301224, at *1. The reasoning set forth in that case applies equally here: The Court is mindful of the liberality of Rule 15(a), yet it does not extend to cases where Plaintiff’s only reason for seeking amendment is to cure a standing defect. If Plaintiff Evenchik is without standing, then amendment would not be allowed, as a plaintiff “may not create jurisdiction by amendment when none exists.” Lans v. Gateway 2000, Inc., 84 F. Supp. 2d 112, 115 (D.D.C. 1999) aff'd, 252 F.3d 1320 (Fed. Cir. 2001) (citations and internal quotations omitted); see also Almeida v. Google, Inc., No. C–08–02088 RMW, 2009 WL 3809808, at *2 (N.D. Cal. Nov. 13, 2009) (“[W]here the original named plaintiff lacks standing, a new plaintiff with standing cannot step in to save the lawsuit from dismissal.”); In re Flash Memory Antitrust Litig., No. C 07–0086 SBA, 2010 U.S. Dist. LEXIS 66466, at *29–30 (N.D. Cal. Jun. 10, 2010) (a party with no standing to maintain an action has no standing to amend). Plaintiff contends that the amendment should be allowed because she has not admitted that she lacks standing and no court has determined that she lacks standing. If the amendment were for another purpose, the Court might agree. Here, though, Plaintiff’s only reason for seeking amendment is to rectify a potential standing defect. If Plaintiff has standing, as Plaintiff maintains, her justification disappears. If she does not, then no amendment is permissible because a plaintiff may not retroactively create jurisdiction. Under the circumstances, the Court is not persuaded that amendment would be proper. Plaintiff's motion is denied.

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Hedayatzadeh v. City of Del Mar, (S.D. Cal. 2020).

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