McCaffrey v. City of Richmond

District Court, N.D. California·Decided June 23, 2025·No. 3:25-cv-03568·Unknown

Opinion

JESSE MCCAFFREY, Case No. 25-cv-03568-WHO

Plaintiff, ORDER ON THE MOTION TO v. DISMISS AND THE MOTION TO STAY; RESCHEDULING CASE CITY OF RICHMOND, et al., MANAGEMENT CONFERENCE Defendants. Re: Dkt. Nos. 7, 15

Plaintiff Jesse McCaffrey (“McCaffrey”) filed this lawsuit pro se in Contra Costa County Superior Court against the City of Richmond and a number of State and local entities and individuals, alleging federal and state law causes of action stemming from the towing of his van, in which he was residing. Four of these defendants (“the City Defendants”) removed the case from state court and now move to dismiss the complaint in full, or, in the alternative, to dismiss those claims that are alleged against them. McCaffrey has sufficiently pleaded his due process claim against the City Defendants. With the opportunity to amend, he may also be able to adequately plead his state law claims against the City Defendants. However, because he legally could not allege facts to plead his first and third causes of action, they are DISMISSED with prejudice. McCaffrey’s Motion to Stay is DENIED. Instead, he should contact the Court’s Legal Help Desk to get support in pursuing his case. He has 60 days from the date of this Order’s filing to file any third amended complaint. Should he fail to file any amended complaint, his case will go forward against the City Defendants only with respect to his second cause of action alleging due process violations. I. Factual Background Jesse McCaffrey is homeless and unsheltered, currently living in West Oakland. Motion to Stay (“MTS”) [Dkt. No. 15] ¶¶ 10–11. These days, he and his 15-year-old dog sleep on a pad under a tarp. Id. He cannot venture too far from his camping area for more than twenty minutes, as he is greatly concerned about theft of his property and the health of his dog. Id. Up until April 10, 2024, he did not have as many concerns as he does today because, although he was still unhoused, he relied on the shelter and security provided by his 1991 Ford E-350 van (“the van”). Second Amended Complaint (“SAC”), Notice of Removal [Dkt. No. 1] Exh. H at 159–190. On that date, he alleges, defendants in this case unlawfully towed the van. McCaffrey alleges that in November of 2020, he purchased the van after receiving his final unemployment benefits. SAC ¶ 28. On November 30, 2022, he submitted a valid smog certificate to the Department of Motor Vehicles (“DMV”), and in January 2023, paid $548.33 for his registration and title transfer fees. Id. He was not able to purchase insurance for the van, because his usual insurer, AAA, no longer offered insurance for the van as a “personal use vehicle,” only for its use as a commercial vehicle. SAC ¶ 30. Although he tried to purchase insurance online through a different insurer, he was unable to do so and was informed that he would need to wait a year to reapply for insurance. Id. In the meantime, he parked the van on private property. Id. In February 2024, seeking an affordable automobile insurance policy, he submitted an application online three times in an effort to get an insurance policy for the van—he never received any follow-up communication from the insurer about a policy. SAC ¶ 31. On February 3, 2024, McCaffrey reached out to the City of Richmond (“the City”) to inquire whether the City had any “safe parking” programs so that he could safely park the van for prolonged periods of time. SAC ¶ 32; SAC Exh. F. The City never responded. SAC ¶ 32. He admits that on several occasions in 2024, he parked the van on a public, residential street, each time for less than 72 hours, in whatever street parking space was nearest to the private property’s private property and not driven.” SAC ¶ 28. Each time he left the van unattended, he posted a notice on the driver’s side window of the van, stating the following: All of the fees required by the DMV to register this vehicle have been paid and a valid smog certificate has been submitted. This vehicle is operational and is only parked here on the street temporarily while a crew working on the house at 5626 Panama Ave requires full access to the driveway for less than 72 hours. The registration not being completed is only due to unexpected issues with obtaining insurance. Due to pursuit of a remedy for prior wrongdoing of a public entity, this vehicle’s owner unfortunately lacks the ability to pay any amount of fine or fee. Additionally, this vehicle currently serves as a temporary shelter for its owner, and therefore there is no need to tow, seize, or impound this vehicle. Thank you for your understanding. SAC ¶ 35. McCaffrey asserts that he had previously interacted with Richmond Parking Enforcement Officer Tiara Gonzales (“Gonzales”), because she posted 72-hour warnings on the van whenever he parked the van on the street. SAC ¶¶ 37–38. He contends that he always complied and moved the van whenever Gonzales posted a notice. SAC ¶ 39. On April 10, 2024, after returning to where he had parked the van on the street, McCaffrey learned that the van had been towed and impounded because of his expired registration. SAC ¶ 41. He alleges that Gonzales contacted Wellsco, Inc. (d/b/a Certified Towing) (“Certified Towing”) to tow the van, without a warrant to do so. He received no notice that his van would be impounded and alleges that there were no outstanding complaints about the van. SAC ¶ 94. That same day, he rode his bike to the Richmond Police Department (“RPD”) police station, to inquire about the whereabouts of the van, ask for its release, and request a tow hearing pursuant to California Vehicle Code § 22852(b)(4). SAC ¶¶ 47, 88. Upon his arrival to the police department, he spoke with an employee at the front desk, who informed him that an officer would be available to speak with him within a few minutes. SAC ¶ 51. McCaffrey was under the impression that his conversation with the officer was a “tow hearing,” but it was not. SAC ¶ 52, 65. The officer refused to release the van, explaining to him that he would need to show proof of current registration before the van could be released. SAC ¶ 52. which he hoped to use to finally make the van’s registration current. SAC ¶ 57–58. However, upon arriving at the DMV, he learned that Certified Towing had initiated a lien on the van. SAC ¶¶ 55, 58. Because of the lien, the DMV informed him, McCaffrey could not complete registration for the van until the lien was rescinded or by court order.1 SAC ¶ 58. While determining next steps, McCaffrey visited the van at the Certified Towing tow yard, and discovered that some of his personal belongings had been scattered throughout the van or removed from the van altogether. SAC ¶ 61. McCaffrey requested an administrative record of the incident, which he received in June 2024. SAC ¶ 65. It was at this time that he learned that the discussion he had with the police officer on April 10, 2024, was not a tow hearing, and that no tow hearing had been held or scheduled, despite his request for one. Id. McCaffrey alleges that the City’s relationship with Certified Towing resulting in the impounding of the van on April 10, 2024, is reflective of their longstanding “policies, customs and/or practices for the handling of Vehicles encountered and impounded under the same or similar circumstances.” SAC ¶ 74. As a part of this practice, the City is able to remove vehicles without warrants, and Certified Towing can “assert an ex parte possessory lien to secure payment of charges relating to the towing, storage, and disposal of the seized vehicles,” benefiting financially without receiving direct payment from the City. SAC ¶¶ 77–81. It is also part of the City’s practice, McCaffrey alleges, that this relationship between the City and Certified Towing does not result in any (1) notice to or (2) hearing for any of those parties’ adversely affected by the towing and impoundment of their vehicle.2 SAC ¶ 84.

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