Keith Bohren v. City of San Jose

CourtDistrict Court, N.D. California
DecidedJuly 20, 2021
Docket5:20-cv-04529
StatusUnknown

This text of Keith Bohren v. City of San Jose (Keith Bohren v. City of San Jose) 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
Keith Bohren v. City of San Jose, (N.D. Cal. 2021).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 ROXANNE BOHREN, Case No. 20-cv-04529-BLF

8 Plaintiff, ORDER GRANTING MOTIONS TO 9 v. DISMISS

10 SAN JOSE POLICE DEPARTMENT, et al., 11 Defendants.

12 13 Before the Court are motions to dismiss by Defendant County of Santa Clara, see County 14 Mot., ECF 36, and Defendants City of San Jose, San Jose Police Department, and San Jose police 15 officer Avila (collectively, “City Defendants”), see City Mot., ECF 37. Plaintiff Roxanne Bohren 16 concedes the dismissal of her operative complaint, the second amended complaint, see SAC, ECF 17 35. Opp’n to County Mot., ECF 39; Opp’n to City Mot., ECF 38 (“Plaintiff basically agrees with 18 much of Defendant City of San Jose’s problem with Plaintiff’s Second Amended Complaint and 19 believes that it can be cured by amending it one last time.”). 20 Ms. Bohren has submitted a proposed third amended complaint. See 3AC, ECF 39-1. Both 21 the City and County Defendants argue that the proposed third amended complaint is still deficient 22 and ask the Court to dismiss this case with prejudice. See County Reply, ECF 41; City Reply, ECF 23 42. The Court GRANTS both unopposed motions to dismiss the second amended complaint. 24 The Court has evaluated Ms. Bohren’s proposed third amended complaint in order to 25 evaluate whether these motions should be granted with leave to amend. See Foman v. Davis, 371 26 U.S. 178 (1962), Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2009). A district 27 court ordinarily must grant leave to amend unless one or more of the Foman factors is present: (1) 1 amendment, (4) undue prejudice to the opposing party, or (5) futility of amendment. Eminence 2 Capital, 316 F.3d at 1052. When evaluating futility, the Court is mindful that, to survive a Rule 3 12(b)(6) motion, a complaint must contain “enough facts to state a claim to relief that is plausible 4 on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility 5 when the plaintiff pleads factual content that allows the court to draw the reasonable inference that 6 the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 7 “The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer 8 possibility that a defendant has acted unlawfully.” Id. (internal quotation marks omitted). In 9 evaluating the complaint, the court must “accept factual allegations in the complaint as true and 10 construe the pleadings in the light most favorable to the nonmoving party.” Manzarek v. St. Paul 11 Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008). 12 Ms. Bohren brings five causes of action stemming from her alleged wrongful arrest and 13 subsequent booking at Santa Clara County’s Main Jail: 1) violation of 42 U.S.C. § 1983 against 14 Defendant Avila for false arrest under the Fourth Amendment; 2) violation of 42 U.S.C. § 1983 15 against Defendant Avila for discriminatory arrest under the Fourteenth Amendment; 3) a Monell1 16 claim against the City and San Jose Police Department; 4) a Monell claim against the County; and 17 5) intentional infliction of emotional distress against Defendant Avila. See 3AC. The Court will 18 review each claim separately. 19 1. Claim One: False Arrest Against Defendant Avila 20 “A claim for unlawful arrest is cognizable under § 1983 as a violation of the Fourth 21 Amendment, provided the arrest was without probable cause or other justification.” Lacey v. 22 Maricopa County., 693 F.3d 896, 918 (9th Cir. 2012) (quoting Dubner v. City & County of San 23 Francisco, 266 F.3d 959, 964 (9th Cir. 2001)). “Probable cause exists when there is a fair 24 probability or substantial chance of criminal activity.” Lacey, 693 F.3d at 918 (quoting United 25 States v. Patayan Soriano, 361 F.3d 494, 505 (9th Cir. 2004)). “It is well-settled that ‘the 26 determination of probable cause is based upon the totality of the circumstances known to the 27 1 officers at the time of the search.’” Lacey, 693 F.3d at 918 (quoting United States v. Bishop, 264 2 F.3d 919, 924 (9th Cir. 2001)). 3 Here, Ms. Bohren has alleged in the third amended complaint that Defendant Avila 4 arrested her while she was walking home. 3AC ¶ 28. Defendant Avila arrested her for allegedly 5 violating California Penal Code 653.22, loitering for the purpose of prostitution, which Ms. 6 Bohren denies, and no charges were ever filed against her. 3AC ¶¶ 28-29, 70. The Court finds that 7 the proposed amendments in the third amended complaint on this claim are not futile. 8 2. Claim Two: Discriminatory Arrest Against Defendant Avila 9 “To prevail on an equal protection claim under the ‘Fourteenth Amendment, a plaintiff 10 must demonstrate that enforcement had a discriminatory effect and the police were motivated by a 11 discriminatory purpose.’” Lacey, 693 F.3d at 920 (quoting Rosenbaum v. City & County of San 12 Francisco, 484 F.3d 1142, 1152 (9th Cir. 2007)). To state a claim, Ms. Bohren “need only allege 13 some facts, either anecdotal or statistical, demonstrating ‘that similarly situated defendants ... 14 could have been prosecuted, but were not.” Lacey, 693 F.3d at 920 (quoting United States v. 15 Armstrong, 517 U.S. 456, 469 (1996)); see also Freeman v. City of Santa Ana, 68 F.3d 1180, 1187 16 (9th Cir.1995) (“[I]t is necessary to identify a ‘similarly situated’ class against which the plaintiff's 17 class can be compared.”). Here, Ms. Bohren has alleged that she, a transgender woman, was 18 arrested by Defendant Avila for walking at night, while men and cisgender women, or women 19 who identify with their sex assigned at birth, are not arrested for walking at night, and the 20 treatment she received was thus discriminatory. 3AC ¶¶ 65-66. The Court finds that the proposed 21 amendments in the third amended complaint on this claim are not futile. 22 3. Claim Three: Monell Claim Against Defendants City of San Jose and San 23 Jose Police Department 24 Ms. Bohren alleges that Defendants City of San Jose and the San Jose Police Department 25 have a long-standing policy of arresting transgender women who walk at night, and Defendants’ 26 customs, practices, and policies demonstrate a deliberate indifference to the constitutional rights of 27 transgender women. 3AC ¶¶ 86-87. “A government entity may not be held liable under 42 U.S.C. 1 behind a violation of constitutional rights.” Dougherty v. City of Covina, 654 F.3d 892, 900 (9th 2 Cir. 2011) (citing Monell, 436 U.S. at 694).

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Keith Bohren v. City of San Jose, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keith-bohren-v-city-of-san-jose-cand-2021.