Krabach v. King County

CourtDistrict Court, W.D. Washington
DecidedJanuary 30, 2024
Docket2:22-cv-01252
StatusUnknown

This text of Krabach v. King County (Krabach v. King County) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Krabach v. King County, (W.D. Wash. 2024).

Opinion

1 The Honorable Barbara J. Rothstein

5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7

8 AMBER KRABACH,

9 Plaintiff, Civil Action No. 2:22-cv-1252-BJR v. 10

ORDER DENYING MOTION FOR 11 KING COUNTY et al., RECONSIDERATION

12 Defendant.

15 I. INTRODUCTION 16 Plaintiff Amber Krabach (“Plaintiff”) instituted this action seeking declaratory and 17 injunctive relief against Defendants King County, Julie Wise in her individual capacity and in her 18 capacity as the Director of King County Elections (“the County Defendants”), Steve Hobbs in his 19 official capacity as Secretary of State of Washington, and Jay Inslee in his official capacity as 20 Governor of the State of Washington (“the State Defendants”). Dkt. No. 70. On October 19, 2023, 21 this Court granted the State Defendants’ motion to dismiss Plaintiff’s Second Amended 22 23 Complaint (“the October 19, 2023 Order”), thereby dismissing the State Defendants from the 24 case. Dkt. No. 107. Currently before the Court is Plaintiff’s motion for reconsideration of the 25 October 19, 2023 Order. Dkt. No. 109. Having reviewed the motion, the State Defendants’ 26 27 1 opposition thereto, Plaintiff’s reply, the record of the case, and the relevant legal authority, the 2 Court denies the motion. The reasoning for the Court’s decision follows. 3 II. PROCEDURAL BACKGROUND 4 This case has an extensive procedural history including an interlocutory appeal, which the 5 Ninth Circuit denied, a request for a second interlocutory appeal, which this Court denied, several 6 7 amended complaints, counterclaims, several motions to dismiss, another request for an 8 interlocutory appeal,1 and now Plaintiff’s motion for reconsideration of the October 19, 2023 9 Order. 10 III. STANDARD OF REVIEW 11 “Under Local Rule 7(h)(1), motions for reconsideration are disfavored, and will ordinarily 12 be denied unless there is a showing of (a) manifest error in the ruling, or (b) facts or legal 13 authority that could not have been brought to the attention of the court earlier, through reasonable 14 15 diligence.” Baker v. New Hanover Regional Hospital, 2022 WL 3577398, *1 (W.D. Wash. Aug. 16 19, 2022). Mere disagreement with an order is an insufficient basis for reconsideration, and 17 reconsideration may not be based on evidence and legal arguments that could have been presented 18 at the time of the challenged decision. See Haw. Stevedores, Inc. v. HT & T Co., 363 F. Supp. 2d 19 1253, 1269 (D. Haw. 2005) (citing Leong v. Hilton Hotels Corp., 689 F. Supp. 1517 (D. Haw. 20 1988)). 21 IV. DISCUSSION 22 23 Plaintiff claims that this Court committed manifest error by (1) misinterpreting the 24 allegations of the second amended complaint, (2) failing to read an “administrative censorship” 25 26 1Plaintiff and the County Defendants voluntarily dismissed their claims against each other without 27 prejudice, mooting this latest request for an interlocutory appeal. Dkt. No. 120. 1 claim into the second amended complaint, and (3) dismissing the State Defendants with prejudice 2 on the sovereign immunity grounds. Plaintiff is incorrect on all three grounds. 3 The factual allegations of Plaintiff’s complaint have been recited by this Court on multiple 4 occasions and will not be restated again here. It is sufficient to say that Plaintiff caused signage to 5 by placed near ballot boxes during the 2022 Washington State primary election. The Country 6 7 Defendants removed the signs, alleging that they violated voter intimidation laws. Plaintiff 8 instituted an action for declaratory and injunctive relief against the State and County Defendants, 9 alleging that the County Defendants removed the signs pursuant to Washington State 10 electioneering laws that, among other things, prohibit political signs within 25 feet of ballot 11 boxes. Plaintiff alleged that removing the signs violated her First Amendment rights. This Court 12 denied Plaintiff’s request for a preliminary injunction because the relief she sought—a declaration 13 that the electioneering laws are unconstitutional—would not redress her alleged injury given that 14 15 the County Defendants removed her signs pursuant to voter intimidation laws, not electioneering 16 laws. 17 Relevant to the instant motion, Plaintiff amended her compliant to include allegations that 18 the State and County Defendants acted pursuant to both voter intimidation and electioneering laws 19 and the State Defendants moved to dismiss Plaintiff’s claims based on the electioneering laws for the 20 same reason that this Court denied Plaintiff’s motion for a preliminary injunction—Plaintiff lacks 21 standing to bring such claims because a favorable decision on those claims would not redress 22 Plaintiff’s alleged injury. This Court agreed with the State Defendants and dismissed Plaintiff’s claims 23 24 based on the electioneering laws. 25 Plaintiff now argues that this Court committed manifest error by dismissing the electioneering 26 law claims. She alleges that this Court “misinterpret[ed] the allegations” in the second amended 27 1 complaint2 and attempts to supplement the allegations with statements made by the King County GOP 2 Chairman Thomas during his deposition testimony. Simply put, it is too late for Plaintiff to bring 3 Chairman Thomas’ testimony to the Court’s attention. Chairman Thomas was deposed on April 18, 4 2023, and the State Defendants filed their motion to dismiss three days later on April 21, 2023. Dkt. 5 Nos. 76, 81. Plaintiff filed her opposition to the motion on May 26, 2023, over a month after the 6 deposition was conducted. This Court did not issue the decision on the motion to dismiss until six 7 months later. During that time, Plaintiff did not bring to the Court’s attention that she believed that the 8 Chairman’s testimony was relevant to the motion to dismiss. She could have cited to the testimony in 9 10 her opposition, requested leave to file a sur-reply, or even sought leave to file a third amended 11 complaint. What she cannot do is wait until the Court issues a determination that is unfavorable to her 12 position and then attempt to circumvent that outcome by bringing pre-existing evidence to the Court’s 13 attention after the fact. See School Dist. No. 1J, Multnomah County, Or. v. ACandS, Inc., 5 F.3d 1255, 14 1263 (9th Cir. 1993) (“The overwhelming weight of authority is that the failure to file documents in 15 on original motion or opposition does not turn the late filed documents into ‘newly discovered 16 evidence.’”), see also Frederick S. Wyle Professional Corp. v. Texaco, Inc., 764 F.2d 604, 609 (9th 17 18 19 20

21 2 Plaintiff suggests that this Court mistakenly concluded from the allegations in the second 22 amended complaint that Plaintiff charged the County Defendants with “formulat[ing] [their] litigation position that [they] acted pursuant to the Intimidation Law only after the initiation of 23 this lawsuit.” Dkt. No. 109 at 4 (emphasis added). The Court reached no such conclusion. The Court simply quoted the foregoing allegation in the complaint as an example of the 24 inconsistencies throughout the complaint. In other words, Plaintiff alleged that while the County Defendants claim that they removed the signs pursuant to voter intimidation laws, she does not 25 believe that is true and, rather, the County Defendants removed the signs pursuant to 26 electioneering laws. But this allegation is inconsistent with many of the other allegations in the complaint, e.g.—Plaintiff alleged that the signs were removed regardless of whether they were 27 within 25 feet of the ballot boxes.

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Bluebook (online)
Krabach v. King County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/krabach-v-king-county-wawd-2024.