Karen Parker v. Juan Prishker; United States of America

District Court, S.D. California·Decided May 11, 2026·No. 3:24-cv-02138·Unknown

Opinion

Case No.: 3:24-cv-2138-L-MSB KAREN PARKER, an individual, ORDER GRANTING PLAINTIFF’S Plaintiff, MOTION FOR LEAVE TO AMEND v. JUAN PRISHKER, an individual; and [ECF No. 31] UNITED STATES OF AMERICA, Defendants.

Pending before the Court is Plaintiff’s motion for leave to file a first amended complaint. (ECF No. 31.) Defendant United States of America (the “Government”) opposed (ECF No. 34), and Plaintiff replied (ECF No. 35). The Court decides the matter on the papers submitted without oral argument. See Civ. LR 7.1(d.1). For the reasons set forth below, Plaintiff’s motion is granted. Plaintiff is a retired social worker who volunteered to ensure timely delivery of medical care to immigrants in the custody of the United States Customs and Border Protection Agency (“CBP”) at the U.S.-Mexico border. (See ECF No. 1, “Compl.”) In this regard, she frequently worked with CBP agents. / / / / / 1 At the relevant time, Plaintiff was volunteering at a CBP open-air detention center and sought to contact a CBP agent to facilitate medical transport for a detainee. She drove to an area where agents were often found. There she encountered agent Juan Prishker alone in his truck and parked beside him. Plaintiff and Prishker stood between their vehicles when Plaintiff asked Prishker about detainee medical transport. Instead of responding to her inquiry, Prishker blocked Plaintiff from her car, showed her photos of his penis, and asked Plaintiff what she thought about them. When Plaintiff tried to retreat to her car, Prishker again blocked her way. In October 2024, Prishker was charged in State court with felony sexual battery and false imprisonment, and with misdemeanor distribution of obscene material. Plaintiff was one of the victims in the criminal complaint. In this action, Plaintiff seeks damages based on allegations of intentional infliction of emotional distress, negligence, and false imprisonment under the Federal Torts Claim Act (“FTCA”). With the pending motion, she requests leave to amend under Federal Rule of Civil Procedure 15(a)(2)1 to add Doe defendants to her negligence claim based on facts discovered in the criminal case. She also requests leave to add State statutory claims alleging gender violence and Bane Act violations. The Government opposes Plaintiff’s motion. Rule 15 provides that “leave shall be freely given when justice so requires.” Fed. R. Civ. Proc. 15(a)(2). “This policy is to be applied with extreme liberality.” Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048, 1051 (9th Cir. 2003).2 Specifically,

1 All future references to “Rule” or “Rules” refer to the Federal Rules of Civil Procedure. 2 Unless otherwise noted, internal quotation marks, ellipses, brackets, citations, and footnotes are omitted from citations. 2 [i]n the absence of any apparent or declared reason—such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc.—the leave sought should, as the rules require, be “freely given.” Foman v. Davis, 371 U.S. 178, 182 (1962). “Not all of the factors merit equal weight. [I]t is the consideration of prejudice to the opposing party that carries the greatest weight.” Eminence Capital, 316 F.3d at 1052. “Absent prejudice, or a strong showing of any of the remaining Foman factors, there exists a presumption under Rule 15(a) in favor of granting leave to amend.” Id. Citing solely its “interest in the expeditious resolution of this case” (ECF No. 34, “Opp’n” at 7), the Government claims, without elaborating, that it would be unduly prejudiced by delay. The Government “bears the burden of showing prejudice.” DCD Programs, Ltd. v. Leighton, 833 F.2d 183, 187 (9th Cir. 1987). This case is in its early stages and well before the close of discovery. (See ECF No. 42, Order Granting Joint Motion to Modify Scheduling Order.) The mere addition of parties and causes of action does not constitute undue prejudice sufficient to deny amendment. DCD Programs, 833 F.2d at 186. Accordingly, the Government has not made an adequate showing of undue prejudice to deny Plaintiff’s motion. The Government next claims that Plaintiff’s proposed amendment would be futile. “[L]eave to amend should be denied as futile only if no set of facts can be proved under the amendment to the pleadings that would constitute a valid and sufficient claim or defense.” Barahona v. Union Pac. R.R, Co., 881 F.3d 1122, 1134 (9th Cir. 2018). A proposed amendment is not futile if it is likely to survive a Rule 12(b)(6) motion to dismiss. See Sonoma County Assoc. of Retired Employees v. Sonoma County, 708 F.3d 1109, 1118 (9th Cir. 2013); see also Krainski v. Nevada. 616 F.3d 963, 972 (9th Cir. 2010) (applying Ashcroft v. Iqbal, 556 U.S. 662 (2009).) 3 The Government advances several futility arguments. First, it maintains that Plaintiff’s proposed addition of two new causes of action is futile as time barred because they were not timely exhausted. Before a plaintiff can file an FTCA action, she must exhaust administrative remedies. 28 U.S.C. § 2675(a). The administrative claim must be presented to the Government “within two years after such claim accrues[.]” 28 U.S.C. § 2401(b). The events underlying Plaintiff’s claims, including the claims she proposes to add, took place in December 2023. (Compl. at 2, 4.) As this was more than two years before Plaintiff filed her pending motion, the Government argues she can no longer administratively exhaust her proposed new claims. However, the FTCA exhaustion requirement “is minimal[.]” Goodman v. United States, 298 F.3d 1048, 1055 (9th Cir. 2002). To meet the requirement, a plaintiff “need only file a brief notice or statement … containing a general description of the time, place, cause and general nature of the injury and the amount of compensation demanded.” Id.; see also Avery v. United States, 680 F.2d 608, 610 (9th Cir.1982) (“[A] skeletal claim form, containing only the bare elements of notice of accident and injury and a sum certain representing damages, suffices[.]”). “[A]dministrative claims are sufficient even if a separate basis of liability arising out of the same incident is pled in federal court.” Goodman, 298 F.3d at 1055. The causes of action Plaintiff proposes to add are based on the same incident as her initial complaint. As the Government does not dispute that Plaintiff’s initial complaint was properly exhausted, Plaintiff’s proposed amended complaint is properly exhausted as well. Second, the Government claims that to the extent Plaintiff’s newly proposed claims are based on failure to properly supervise Prishker, the claims are barred by the discretio

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Karen Parker v. Juan Prishker; United States of America, (S.D. Cal. 2026).

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