McCormick v. County of San Diego

CourtDistrict Court, S.D. California
DecidedMarch 10, 2021
Docket3:20-cv-01753
StatusUnknown

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

Bluebook
McCormick v. County of San Diego, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 DIANNE McCORMICK, Case No.: 20cv1753 JM (AGS)

12 Plaintiff,

13 v. ORDER ON MOTION TO DISMISS PLAINTIFF’S FIRST AMENDED 14 COUNTY OF SAN DIEGO, SAN DIEGO COMPLAINT SHERIFFS DEPUTIES; DOES 1-10, 15 Defendants. 16 17 18 The County of San Diego (“the County) moves to partially dismiss Plaintiff’s First 19 Amended Complaint (“FAC”) pursuant to Federal Rule of Civil Procedure 12(b)(6). (Doc. 20 No. 13.) The motion has been fully briefed and the court finds it suitable for submission 21 without oral argument in accordance with Civil Local Rule 7.1(d)(1). For the below 22 reasons, the motion is DENIED IN PART and GRANTED IN PART. 23 I. BACKGROUND 24 In her FAC, Plaintiff alleges that on the morning of January 11, 2020, deputy sheriffs 25 came onto her property and asked to speak with Ms. Clark, the girlfriend of Plaintiff’s 26 tenant. (FAC ¶ 9.) The Deputies were there to perform a “Fourth Waiver compliance 27 check” on Ms. Clark, a parolee. (Id.) Plaintiff did not know why the Deputies were asking 28 to speak with Ms. Clark, and the Deputies did not tell her why. (Id.) Plaintiff led the 1 deputies by foot down the road, up the driveway, up the walkway, and up the stairs to see 2 if the front door was unlocked. (¶ 10.) According to Deputy Norby’s report, Detective 3 Castro and Deputy Norby each advised her not to enter her home. (Id.) Plaintiff denies 4 that any such warning or command was given. (Id.) 5 As she was halfway inside the open front door, Deputy Norby, without warning, 6 grabbed her left arm and forcefully pulled her backward into the door jam, then forced her 7 down to the ground. (¶ 11.) As Deputy Norby handcuffed her, Deputy Krawczyk pulled 8 her head back by her ponytail and slammed her head onto the hardwood floor. (Id.) She 9 was placed under arrest for violating California Penal Code § 148(a)(1). (Id.) The San 10 Diego County District Attorney’s Office later declined to issue charges. (Id.) 11 Plaintiff brings claims for: (1) false arrest under federal law; (2) excessive force 12 under federal law; (3) negligence; (4) false arrest under California law; (5) battery; and 13 (6) violation of the Bane Act, California Civil Code § 52.1(b). Plaintiff seeks 14 compensatory damages, punitive damages, attorneys’ fees, and costs. The County moves 15 to dismiss Plaintiff’s claims for false arrest, as well as her Bane Act claim. (Doc. No. 13.) 16 The County also requests the court take judicial notice of body worn camera video footage 17 of the arrest, as well as some still frames of the video. (Doc. No. 13-2.) 18 II. LEGAL STANDARDS 19 In deciding a motion to dismiss a complaint under Rule 12(b)(6), the court must 20 “take all allegations of material fact as true and construe them in the light most favorable 21 to the non-moving party.” Parks Sch. of Bus. v. Symington, 51 F.3d 1480, 1484 (9th Cir. 22 1995). The court must also draw all reasonable inferences in favor of the claimant. Retail 23 Prop. Trust v. United Bhd. of Carpenters & Joiners of Am., 768 F.3d 938, 945 (9th Cir. 24 2014). Dismissal may be based on a lack of a cognizable legal theory or on the absence of 25 facts that would support a valid theory. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 26 699 (9th Cir. 1990). A complaint “‘must contain either direct or inferential allegations 27 respecting all the material elements necessary to sustain recovery under some viable legal 28 theory.’” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 562 (2007) (quoting Car Carriers, 1 Inc. v. Ford Motor Co., 745 F.2d 1101, 1106 (7th Cir. 1984)). “A pleading that offers 2 ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will 3 not do.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 555). 4 “[C]ourts ‘are not bound to accept as true a legal conclusion couched as a factual 5 allegation.’” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 6 (1986)). Rather, the claim must be “‘plausible on its face,’” meaning that the plaintiff must 7 plead sufficient factual allegations to “allow[] the court to draw the reasonable inference 8 that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (quoting 9 Twombly, 550 U.S. at 570). In pursuing a motion to dismiss, the defendant bears the burden 10 of showing the plaintiff has failed to state a plausible claim. See Shay v. Apple Inc., Case 11 No.: 20cv1629-GPC(BLM), 2021 WL 75690, at *3 (S.D. Cal. Jan. 8, 2021). 12 III. DISCUSSION 13 A. Body Camera Video 14 As an initial matter, the County requests the court take judicial notice of body camera 15 video and audio of the incident leading to Plaintiff’s arrest (“the recording”), as well as 16 some still frames of the video, under Rule 201 of the Federal Rules of Evidence. (Doc. 17 No. 13-2 at 1.) The County also argues the recording is incorporated by reference into the 18 FAC. (Id. at 2-3.) Plaintiff does not oppose judicial notice of the recording, but opposes 19 judicial notice of the still frames because “videos are more authentic” and photographs 20 “lack the necessary context.” (Doc. No. 14 at 8 n.1.) 21 Judicial notice permits a court consider an adjudicative fact if it is “not subject to 22 reasonable dispute.” Fed. R. Evid. 201(b). A fact is “not subject to reasonable dispute” if 23 it “can be accurately and readily determined from sources whose accuracy cannot 24 reasonably be questioned.” Fed. R. Evid. 201(b)(1)-(2). A court may take judicial notice 25 of matters of public record without converting a motion to dismiss into a motion for 26 summary judgment. Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1002 (9th Cir. 27 2018) (citing Lee v. City of Los Angeles, 250 F.3d 668, 688 (9th Cir. 2001)). 28 1 “Unlike rule-established judicial notice, incorporation-by-reference is a judicially 2 created doctrine that treats certain documents as though they are part of the complaint 3 itself.” Khoja, 899 F.3d at 1002. Courts “are permitted to consider documents that were 4 not physically attached to the complaint where the documents’ authenticity is not contested, 5 and the plaintiff’s complaint necessarily relies on them.” Sams v. Yahoo! Inc., 713 F.3d 6 1175, 1179 (9th Cir. 2013). 7 In cases where the plaintiff objects to the court’s consideration of police body camera 8 or dashboard camera video in deciding a motion to dismiss, district courts consistently 9 decline, under Sams, to consider the video under the incorporation by reference doctrine. 10 See Estate of Smith v. City of San Diego, Case No.: 16-cv-2989-WQH-MDD, 2018 WL 11 3706842, at *3 (S.D. Cal. Aug. 3, 2018) (plaintiff argued the complaint did not necessarily 12 rely on numerous videos of a police shooting submitted by the defendants); Lee v.

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McCormick v. County of San Diego, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccormick-v-county-of-san-diego-casd-2021.